Overview
- Interpretive Letter 1186 permits OCC‑supervised institutions to hold native tokens as principal when needed to pay network fees, receive validator fees, facilitate blockchain transactions, or test crypto platforms.
- The authorization is strictly operational and does not permit speculative trading or proprietary crypto desks.
- Banks must limit holdings to "reasonably foreseeable" needs and apply market, liquidity, operational, cyber, and BSA/AML controls.
- The OCC says direct token holdings can reduce counterparty and process risk by eliminating reliance on third parties for gas payments.
- The policy applies to national banks and federal savings associations, while the Federal Reserve continues to deem principal crypto holdings by state member banks unsafe and unsound.