The second charter of the day draws the line the first one crossed

What happened

The Office of the Comptroller of the Currency granted preliminary conditional approval on 2 September 2026 to charter Revolut Bank US, National Association, a full-service insured national bank in Stamford, Connecticut with no branches and no trust powers, wholly owned by Revolut Holdings US, Inc. The letter is Corporate Decision #1390, signed by Stephen Lybarger, Senior Deputy Comptroller for Chartering, Organization and Structure, answering an application filed on 10 March 2026 under 12 USC 21-27 and 12 CFR 5.20 with proposed charter number 25420. It is dated the same day as Corporate Decision #1389, which chartered OpenReserve, and the agency again published no press release for either: its numbered 2026 news release series still stops at nr-occ-2026-74. The digital asset perimeter is drawn tightly and in terms. The bank will offer custody of digital assets, 'e.g. hosting wallets, custodian cryptocurrencies', 'in a nonfiduciary capacity through its affiliate Revolut Ltd (TechCo)', a UK company the Financial Conduct Authority regulates under the Electronic Money Regulations 2011. 'Total digital asset services revenue across retail and business is projected to be less than 2 percent of the total Bank revenue over the three-year de novo period.' 'The Bank does not intend to hold any digital assets on its balance sheet.' Customers, including deposit account holders and custody customers, may 'pay remittances (i.e., cross-border money transfers) using digital assets, including stablecoin', which the OCC permits on Interpretive Letter 1174 of January 2021. And on the group's own token: 'The Bank plans to offer Revolut-branded stablecoins through a third-party. The Bank will not be the issuer and will not be managing any of the reserves related to the Revolut-branded stablecoins. The Bank's role with regard to Revolut stablecoins will be limited to marketing and providing customer access and custody through TechCo', with an undertaking to comply with the GENIUS Act once it and its regulations take effect. Four conditions attach, including sixty days notice and written no objection before any significant change to the business plan, a tier 1 leverage ratio of no less than 10.0 per cent for three years, and a written no objection before the bank offers any foreign exchange forward, merchant acquiring or foreign non-affiliate correspondent banking product. The approval expressly 'does not include the proposed retail foreign exchange business'. Among the preopening requirements is a capital plan that identifies 'off-balance sheet risks arising from digital asset custody and related activities'. Initial paid-in capital must be at least $95m, and the OCC received three comment letters and found no significant issue in them. The Block reports that the group holds bank licences in France, Australia and the United Kingdom, quotes chief executive Nik Storonsky calling the approval 'an important first step' that 'gives us the foundation to build in the world's largest financial market and bring the full Revolut experience to millions of Americans', and puts the OCC's record since 2025 at 40 de novo charter applications received, 21 approved and two denied.

Why it matters

Two charter letters left the same office on the same day and they are not the same document. OpenReserve's puts tokenized capabilities across every deposit product and contemplates a wholly-owned subsidiary issuing dollar stablecoins, with the first condition reserving to the OCC, in its sole discretion, the judgment of whether that complies with GENIUS Act rules not yet written. Revolut's does the opposite on every one of those points: no issuance, no reserve management, no digital asset on the balance sheet, custody pushed out to an affiliate that a foreign regulator supervises as an e-money institution rather than as a bank, and a projection that the whole activity stays under 2 per cent of revenue for three years, which the first condition makes hard to exceed without the agency's leave. Read together they show the Comptroller is not applying a single template to firms with digital asset plans. It is pricing each plan, and the price of a full-service retail charter for a foreign payments group is that the token stays outside the bank. The structural point is the one the industry will argue about. Revolut will market a stablecoin bearing its own name, give customers access to it and custody it, while an unnamed third party issues it and holds the reserves. That is distribution without issuance, and it is a shape the GENIUS Act framework has not yet been tested on: the brand a customer trusts and the balance sheet that stands behind the token belong to different companies, and only one of them is supervised by the OCC.

What is not settled

The bank does not exist and may not. It must obtain FDIC deposit insurance, which is under review, apply for Federal Reserve Bank stock, and see its parents approved as bank holding companies by the Federal Reserve; the letter says the bank 'may not begin the business of banking' until it meets every preopening requirement and the OCC grants final approval, and the approval expires if capital is not raised within twelve months or the bank is not open within eighteen. On the digital asset side almost nothing is named. The letter does not identify the third party that would issue the Revolut-branded stablecoins, the reserve arrangement, the chain, the currencies, or whether the token would be a permitted payment stablecoin under the GENIUS Act at all; nor does it say which digital assets TechCo would custody, or how a custody service run from a UK e-money institution is supervised when the customer's account is at a US national bank. It does not explain what the retail foreign exchange carve-out is for, beyond pointing at 12 CFR 48.4. Three comment letters were received and the letter neither names the commenters nor summarises what they said. And no report read here established whether the group has applied anywhere for a stablecoin issuance licence of its own.