RIADeFi

OCC permits banks to hold limited crypto as principal for network fees and testing

Regulation · · Ketju Research

Office of the Comptroller of the Currency

What changed

The OCC confirmed that national banks may hold limited amounts of crypto assets on balance sheet to pay blockchain network fees for permissible activities and to test permissible platforms. The authority is incidental and bounded by reasonably foreseeable operational need, safe-and-sound practices, and applicable law.

Who it affects

  • National banks operating crypto custody or settlement services
  • Advisers evaluating bank onchain execution and custody capabilities

What is still open

  • Bank-specific limits, accounting, controls, and supported networks
  • How banks will address volatility, forks, sanctions, and operational incidents

What it means for an advisor

  • Confirm how a bank sources, safeguards, values, and accounts for fee assets
  • Do not characterize limited incidental holdings as broad bank authority to speculate in crypto assets

Previous interpretation

Bank authority to hold crypto as principal for gas fees and platform testing had not been expressly confirmed in this form.

Sources

  1. Interpretive Letter 1186 · Office of the Comptroller of the Currency ·

Version 1, published . Educational analysis, not legal advice.