The Office of the Comptroller of the Currency (OCC) has granted OpenReserve preliminary conditional approval to establish a full-service insured national bank in Salt Lake City, Utah.
The approval, issued on 2 September, does not yet permit OpenReserve Bank to begin operations. Before it can open, the company must raise at least $210m, secure deposit insurance and meet the OCC’s requirements on capital, governance, technology, security and regulatory compliance.
OpenReserve applied for a national bank charter on 13 April. Its proposed institution would combine conventional banking with digital asset services, setting it apart from limited-purpose national trust banks.
The bank intends to offer deposit accounts, commercial and retail lending, treasury management, payment services and foreign correspondent banking. Some deposit products could include tokenised features, according to the OCC’s eight-page decision.
It also plans to provide digital asset custody through a subsidiary. Customers could use assets including stablecoins for cross-border remittances and other payment activities permitted under US law.
OpenReserve could receive transaction fees in cryptocurrency, although it would generally be required to convert those assets into fiat currency within one business day. An exception would apply where retaining the cryptocurrency served another permitted purpose, such as covering expected blockchain gas fees.
“OpenReserve Bank is our contribution to that tradition: durable financial infrastructure, built in the United States,” CEO Dee Choubey said.
The services outlined in the application remain subject to final approval, detailed product development, customer eligibility requirements and the bank’s operational readiness.
Capital and launch deadlines
The OCC has stipulated that OpenReserve must raise at least $210m in initial paid-in capital after organisational and pre-opening expenses have been covered. It must also maintain a tier-one leverage ratio of at least 12% during its first three years.
The capital must be secured within 12 months of the conditional approval. Banking operations must begin within 18 months, otherwise the approval will expire unless the OCC determines that circumstances outside the organisers’ control caused the delay.
OpenReserve must apply for Federal Reserve Bank stock and obtain insurance from the Federal Deposit Insurance Corporation (FDIC). Its charter request was submitted alongside an application for federal deposit insurance.
At least 60 days before the proposed opening date, the company must notify the OCC. The regulator will then carry out a pre-opening examination covering the bank’s technology, governance, compliance systems and overall readiness.
Stablecoin plans require separate application
OpenReserve also intends to create a wholly owned subsidiary focused on issuing, holding, converting and processing US dollar-backed stablecoins. The OCC said no application for that subsidiary has yet been submitted.
Any such activity would have to comply fully with the GENIUS Act and its implementing regulations. The OCC would retain sole discretion over whether OpenReserve’s proposed structure and activities met those requirements.
The company must provide at least 60 days’ notice before making a material change to its business plan. It cannot implement such a change until the OCC gives written confirmation that it has no objection.
OpenReserve has said its planned on-chain ledger and stablecoin infrastructure would support continuous settlement. Those capabilities are proposed for the future and are not currently available to customers.
Regulatory checks before opening
The company must establish programmes covering the Bank Secrecy Act, sanctions compliance, credit risk and information security. It must also appoint an independent auditor and prepare accounts in accordance with generally accepted accounting principles.
An independent reviewer will be required to test the proposed electronic platform, including safeguards against unauthorised access, malicious software and denial-of-service attacks. The OCC must approve the final technology architecture and associated risk-management plan.
OpenReserve has announced seed backing from Andreessen Horowitz, Jump Capital, Coinbase Ventures, Wintermute Ventures and several other investors. It has not disclosed the amount raised or confirmed how much of that funding would count towards the $210m capital requirement.
The decision comes as more digital asset companies seek federal oversight. 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 sought limited-purpose trust charters. OpenReserve’s plans for insured deposits and lending distinguish it from companies such as Crypto.com, whose proposed trust bank would concentrate on custody and settlement without accepting deposits or issuing traditional loans.
The OCC can amend, suspend or withdraw OpenReserve’s approval before the bank opens. Final authorisation remains dependent on the company completing all pre-opening conditions within the regulator’s deadlines.
