OCC Lets National Banks Hold Limited Crypto for Network Fees and Testing
OCC Interpretive Letter 1186 clarified that national banks could hold limited amounts of crypto assets as principal when needed to pay blockchain network fees or test otherwise permissible services.
On November 18, the Office of the Comptroller of the Currency issued Interpretive Letter 1186, clarifying that national banks may hold limited amounts of crypto assets as principal when the holdings are reasonably necessary to engage in otherwise permissible banking activities. Examples included paying blockchain network fees and testing crypto-asset platforms and services.
The letter addressed an operational problem. A bank can have authority to provide custody or blockchain-related services yet still need a small amount of a network’s native asset to test systems or pay transaction fees. By allowing limited principal holdings for those purposes, the OCC reduced uncertainty around the mechanics of actually operating such services.
The interpretation applied to crypto assets generally rather than Bitcoin alone, but it materially affected banks seeking to interact with Bitcoin and other blockchain networks. It was distinct from the OCC’s later December guidance on riskless-principal crypto transactions: November’s action dealt with limited operational holdings needed to run and test bank services.