OpenReserve Wins Conditional OCC Approval for a National Crypto Bank

OpenReserve’s OCC approval is conditional, not a bank launch

The OCC’s application database lists OpenReserve’s new-bank filing as approved on Sept. 2. The decision covers a proposed full-service insured national bank with its main office in Salt Lake City and no branches.

The distinction matters. A preliminary conditional approval is an authorization to organize toward opening, not a final charter to conduct banking. The agency says final approval will not be granted until the bank satisfies preopening requirements, including an OCC examination and the other required regulatory approvals.

OpenReserve must also maintain a Tier 1 leverage ratio of at least 12% through its first three years of operation. If it does not raise the required capital within 12 months, or does not open within 18 months of the approval date, the OCC decision says the approval expires absent an extension.

That is a notably different milestone from a crypto company’s conditional trust-bank permission. Coinbase’s Abu Dhabi authorization also involved a regulated route to digital-asset services, but it did not represent a U.S. full-service national-bank opening.

The OCC’s order says OpenReserve must give at least 60 days’ notice and receive a written no-objection determination before making significant changes to its business plan during organization and its first three years. It also requires an independent security review and testing of its electronic banking platform before the preopening examination.

Tokenized deposits and stablecoin plans remain proposals

The OCC describes a broad proposed business: deposit and lending products with tokenized capabilities, payments and treasury services, digital-asset services, foreign correspondent banking and a banking-as-a-service platform.

It also says the company plans a wholly owned stablecoin subsidiary for issuance, custody, conversion and payment of U.S. dollar reserve-backed stablecoins. Crucially, the decision states that an application for that subsidiary has not yet been filed.

The proposed bank would provide nonfiduciary digital-asset custody through the subsidiary, the OCC said. It would receive digital assets as transaction fees and could hold amounts on balance sheet for expected network fees, a narrower authority than holding crypto as an unrestricted investment position.

The regulator also required any stablecoin issuance and structure to comply with the GENIUS Act and future implementing rules where applicable. That leaves the name, timing, reserve arrangements, redemption mechanics, supported networks and customer eligibility for any proposed stablecoin undisclosed.

OpenReserve’s framing joins a growing effort to bring digital-dollar functions within bank oversight. It is different from a stablecoin issuer’s own charter path, such as World Liberty’s conditional OCC charter for USD1, because OpenReserve is proposing deposits, lending and treasury services alongside its future stablecoin plans.

$210 million capital test is OpenReserve’s next hurdle

The OCC requires OpenReserve to have no less than $210 million in initial paid-in capital, net of organizational and preopening expenses. The capital must be raised in the manner described in its application unless the company first notifies the OCC in writing.

That requirement is more than eight times the $25 million seed round OpenReserve disclosed. The company and a16z crypto have described the round as seed financing, while the agency’s capital condition applies to the bank’s opening balance sheet after expenses.

OpenReserve said its intended platform would serve institutional customers across treasury management, stablecoin issuance and tokenized deposits. The company said in its announcement that no product or service described for the proposed bank is currently offered unless expressly stated otherwise.

The proposed bank is entering a policy environment where companies are trying to connect traditional banking with tokenized cash and settlement. That overlap has expanded through pilots such as Visa’s private stablecoin settlement test, though a payment pilot and a new national bank remain fundamentally different forms of authorization and risk.

Crypto market sentiment was in greed territory at the research check. Alternative.me’s Crypto Fear and Greed Index stood at 73 out of 100 on Sept. 6, a Bitcoin-focused measure that does not evaluate OpenReserve’s capital plan, licensing status or future services.

The next concrete checkpoints are the capital raise, FDIC and Federal Reserve actions, the OCC preopening review, and any separate stablecoin-subsidiary filing. Until those occur, OpenReserve is a nationally chartered bank in organization with conditional approval, not an operating crypto bank.