The Office of the Comptroller of the Currency granted OpenReserve preliminary conditional approval on Sept. 2 to organize a full-service insured national bank in Salt Lake City, Utah.
Summary
- OCC granted OpenReserve preliminary conditional approval to organize a full-service insured national bank in Utah.
- OpenReserve must raise at least $210 million and obtain deposit insurance before receiving final authorization.
- The proposed bank plans deposits, lending, digital asset custody, tokenized deposits and treasury payment services.
- A stablecoin subsidiary remains unfiled and future issuance must comply with the GENIUS Act fully.
- Preliminary approval expires unless capital arrives within twelve months and banking begins within eighteen months.
The approval does not allow OpenReserve Bank to begin banking operations. The company must satisfy the OCC’s capital, governance, security and compliance requirements before receiving final authorization.
OpenReserve plans a full-service national bank
OpenReserve applied for a national bank charter on April 13. Unlike limited-purpose national trust banks, its proposed institution would accept insured deposits and offer conventional lending alongside digital asset services.
The bank plans deposit products, commercial and retail lending, treasury management, payments and foreign correspondent banking. Its deposit products could include tokenized capabilities, according to the OCC’s eight-page decision.
OpenReserve also intends to provide digital asset custody through a subsidiary. Customers could use digital assets, including stablecoins, for cross-border remittances and other permitted payment activities.
The bank could receive transaction fees in cryptocurrency. It would generally need to convert those assets into fiat within one business day unless retaining them serves another permitted purpose, such as paying anticipated blockchain gas fees.
“OpenReserve Bank is our contribution to that tradition: durable financial infrastructure, built in the United States,” CEO Dee Choubey said.
The proposed services remain subject to final approval, product design, customer eligibility and operational readiness.
OCC requires $210 million before opening
The OCC requires OpenReserve to raise at least $210 million in initial paid-in capital after organizational and preopening expenses. The bank must maintain a tier-one leverage ratio of no less than 12% during its first three years.
OpenReserve must raise the capital within 12 months of conditional approval. It must begin banking operations within 18 months or the approval will expire, except in circumstances the OCC considers beyond the organizers’ control.
The company must apply for Federal Reserve Bank stock and obtain deposit insurance from the Federal Deposit Insurance Corporation. The charter application was submitted as a joint national bank and federal deposit insurance filing.
OpenReserve must notify the OCC at least 60 days before its proposed opening date. The regulator will then conduct a preopening examination covering operational readiness, governance, compliance and technology.
Stablecoin subsidiary requires a separate filing
OpenReserve plans to establish a wholly owned subsidiary for issuing, holding, converting and processing U.S. dollar-backed stablecoins. However, the OCC said an application for that subsidiary has not been filed.
Any stablecoin activities must comply with the GENIUS Act and its implementing regulations. The OCC retains sole discretion to determine whether OpenReserve’s structure and activities meet those requirements.
The bank must also give the regulator at least 60 days’ notice before materially changing its business plan. It cannot proceed with such a change until the OCC issues a written determination of no objection.
OpenReserve has described its planned onchain ledger and stablecoin infrastructure as supporting continuous settlement. These are intended capabilities, not services currently available to customers.
Security and compliance reviews come before launch
OpenReserve must establish programs covering the Bank Secrecy Act, sanctions compliance, credit risk and information security. It must also appoint an independent auditor and prepare financial statements under generally accepted accounting principles.
An independent reviewer must test the bank’s electronic platform, including protections against unauthorized access, malicious software and denial-of-service attacks. The OCC must also approve the final technology architecture and related risk-management plan.
OpenReserve announced seed backing from Andreessen Horowitz, Jump Capital, Coinbase Ventures, Wintermute Ventures and several other investors. It did not disclose the amount raised or confirm how much would count toward the $210 million requirement.
The decision arrives as more digital asset companies seek federal supervision. Crypto.news previously reported that the OCC listed 13 pending digital asset applications in August as Comptroller Jonathan Gould encouraged permissible crypto businesses to pursue national charters.
Most recent applicants have pursued limited-purpose trust charters. OpenReserve’s planned insured deposits and lending distinguish it from firms such as Crypto.com, whose proposed trust bank would focus on custody and settlement without accepting deposits or issuing traditional loans.
The OCC can modify, suspend or withdraw OpenReserve’s approval before opening. Final authorization depends on the company completing every preopening condition within the regulator’s deadlines.
