The OCC charters a bank that means to tokenize every deposit it takes

What happened

The Office of the Comptroller of the Currency granted preliminary conditional approval on 2 September 2026 to charter OpenReserve Bank, National Association, a full-service insured national bank with its main office in Salt Lake City, Utah and no branches. The letter is Corporate Decision #1389, signed by Stephen A. Lybarger, Senior Deputy Comptroller for Chartering, Organization and Structure, and answers an application filed on 13 April 2026 under 12 USC 21-27 and 12 CFR 5.20 with proposed charter number 27203. The approved business plan is a full-service bank offering 'deposit and lending products, including tokenized capabilities across all deposit products, as well as payments and treasury services, digital asset services, foreign correspondent banking, and a range of additional services through a full-service banking-as-a-service platform'. Beside that: 'The Bank plans to form a wholly-owned stablecoin subsidiary to engage in issuance, custody, conversion, and payment of U.S. dollar-denominated reserve-backed stablecoins. An application for the subsidiary has not yet been filed.' The same subsidiary would custody digital assets in a non-fiduciary capacity, the bank would take its fees deducted from customer transactions in digital assets, and it would hold digital assets on its own balance sheet to pay network fees, 'commonly referred to as "gas fees"', which the OCC permits on Interpretive Letter 1186 of 18 November 2025. Four conditions attach. The first requires the bank to conform its activities, 'including stablecoin issuance', to the GENIUS Act and any implementing regulations that take effect in future, 'such compliance to be determined in the sole discretion of the OCC'. The third sets a tier 1 leverage ratio of no less than 12.0 per cent through the first three years. Initial paid-in capital must be at least $210m net of organizational and preopening expenses. The OCC posed no objection to eleven named organizers, directors and officers, led by Diwakar Choubey as chief executive and Richard Correia as president and chief operating officer, and waived the director residency requirement for seven of them. The Block and PYMNTS report a $25m seed round led by a16z crypto with Jump Capital, Acrew, Coinbase Ventures and Wintermute Ventures among others; PYMNTS quotes Choubey calling the approval 'a significant milestone and the beginning of the most demanding phase of the work' and a16z general partner Guy Wuollet saying 'We need a bank that's always on, always open, always available. A bank that never closes.'

Why it matters

The run of crypto charters the OCC's own 14 August decision listed in its footnotes, BitGo, Circle's First National Digital Currency Bank, Fidelity Digital Assets, Paxos National Trust, Ripple, Bridge and Foris DAX, were all national trust banks. A trust bank cannot take insured deposits and cannot lend. This one can do both, which changes what the tokenized dollar on the other side is: not a stablecoin backed by a reserve pool held outside the banking system, but a deposit on the balance sheet of an insured bank that can lend against it and that a supervisor examines. That is the same structure thirty regional banks are building collectively through Cari on the same day, arrived at from the opposite direction, and it is the structure Singapore's proposal published the day before deliberately separates from stablecoin issuance. The first condition is the part worth reading twice. The GENIUS Act's implementing rules are not written, and rather than wait, the OCC has granted the charter and reserved to itself, in its sole discretion, the judgment of whether whatever the bank eventually does with its stablecoin subsidiary complies with them. The agency is licensing a business model before the rulebook for half of it exists, and keeping the power to define compliance as it goes.

What is not settled

Nothing has opened. The letter says the bank 'may not begin the business of banking until it fulfills all requirements for a bank in organization and the OCC grants final approval', and the agency reserves the right to modify, suspend or rescind. The $210m of paid-in capital has to be raised within twelve months against a reported $25m seed, the bank has to be open within eighteen or the approval expires, deposit insurance from the FDIC has not been obtained and Federal Reserve Bank stock has not been applied for. Because no application for the stablecoin subsidiary has been filed, nothing about the token exists on any record: no name, no chain, no reserve arrangement, no redemption terms. The letter does not say what 'tokenized capabilities across all deposit products' means in practice, on which ledger, or whether the tokens would move between banks at all. And the OCC published no press release: its numbered 2026 series runs to nr-occ-2026-74 and none of those releases announces this charter, so the decision letter is the whole of the public record, which is the same pattern the desk found on the World Liberty charter of 14 August.