OCC Grants Conditional Approval for Blockchain-Native Bank
Salt Lake City, UT – OpenReserve Bank, a fintech startup backed by prominent venture capital firms including Andreessen Horowitz, has received preliminary conditional approval from the Office of the Comptroller of the Currency (OCC) to establish a full-service national bank in Salt Lake City, Utah. The decision, issued on September 2, concludes a review process that began with OpenReserve’s application on April 13.
OpenReserve Bank, which secured $25 million in seed funding led by a16z crypto with participation from Coinbase Ventures, Jump Capital, and Wintermute Ventures, is positioning itself as an “always-on” bank. Its model centers on continuous, blockchain-based settlement, a departure from the batch-processing systems like ACH and wire transfers used by traditional financial institutions.
The approval is contingent upon OpenReserve meeting specific financial benchmarks. The bank must raise at least $210 million in initial paid-in capital, after accounting for organizational costs. Additionally, it is required to maintain a Tier 1 leverage ratio of at least 12% throughout its first three years of operation. Failure to meet the capital requirement within 12 months or to open for business within 18 months will result in the expiration of the approval.
Diwakar Choubey, co-founder of OpenReserve and former executive at MoneyLion, emphasized that the decision to pursue a full-service national bank charter, rather than the national trust charter favored by many “crypto banks,” was a deliberate strategic choice. “We chose the national bank path deliberately,” Choubey stated in an announcement.
This approach distinguishes OpenReserve from many of its peers in the cryptocurrency space. Companies such as Coinbase, Circle, Ripple, Paxos, and BitGo have opted for national trust charters, which permit custody and fiduciary services but prohibit deposit-taking and lending activities. A full national bank charter, once fully approved, will enable OpenReserve to engage in both.
OpenReserve’s business strategy is built around tokenized deposits, treasury management, foreign correspondent banking, and a banking-as-a-service platform for institutional clients. The company also plans to establish a separate, wholly owned subsidiary to issue and redeem U.S. dollar-denominated, reserve-backed stablecoins. This subsidiary has not yet filed its own OCC application, and any stablecoin activities will need to comply with the GENIUS Act, the federal law governing stablecoin operations that took effect in July of last year.
OpenReserve is not the only firm to receive a charter this week. The OCC also granted preliminary conditional approval to British fintech Revolut for a national bank based in Connecticut. Comptroller Jonathan Gould has described these approvals as part of an effort to integrate firms developing novel technologies into the federally supervised banking system.
However, the OCC’s approach to chartering has faced scrutiny. In May, Senator Elizabeth Warren argued that a series of OCC approvals for crypto trust banks contravened the National Bank Act, stating that these firms “look like crypto banks, not trust companies.” Despite these concerns, the OCC proceeded to approve a national trust charter for the World Liberty stablecoin venture, which has ties to Donald Trump, in August.
Under the current preliminary approval, OpenReserve has until September 2027 to secure the $210 million in capital and until March 2028 to commence operations. Failure to meet either of these deadlines will lead to the expiration of the conditional approval.
