Overview
- The OCC issued Interpretive Letter 1188 allowing national banks to conduct riskless-principal crypto transactions by buying from one party and immediately reselling to a customer.
- The agency frames the activity as the legal and economic equivalent of brokerage, with market risk offset but credit and settlement risks subject to controls and examination.
- Banks can offer direct crypto execution alongside custody without holding assets in inventory except in rare settlement failures, with activities reviewed through routine supervision.
- Comptroller Jonathan Gould defended OCC reviews of crypto trust-charter applications, citing 14 de novo filings in 2025 and conditional approval for Erebor.
- The OCC has removed references to “reputation risk” from guidance and, with the FDIC, is moving to codify its elimination as part of a broader 2025 reset that includes rescinded restrictions and the GENIUS Act.