The OCC quietly returned Zerohash's national trust bank charter application without issuing a formal approval or denial, marking the first publicly known instance of such a procedural return for a digital asset firm. The move was not announced and carries no official explanation, leaving the industry to interpret it as a signal of deficiencies in the filing or heightened internal review standards. Zerohash has stated it plans to refile this month. For Armada's crypto desk, this episode underscores the fragility of the regulatory pathway for digital asset custody entities. Firms relying on OCC charter status for counterparty legitimacy or custody architecture may face delays, and Armada's own due diligence on custody partners like Fireblocks should account for evolving OCC standards around charter eligibility.