Overview
- Interpretive Letter No. 1186, issued Nov. 18, authorizes national banks and federal savings associations to hold limited native tokens as principal to pay blockchain network fees and to test otherwise permissible crypto platforms.
- Holdings must cover only "reasonably foreseeable" fee obligations and remain de minimis relative to capital, with activities conducted in a safe and sound manner and in full legal compliance.
- The OCC grounded its decision in incidental‑to‑banking authority and referenced a three‑part compliance program: risk and compliance assessment, procedures to measure and manage risks including AML and cybersecurity, and strict limits on token balances.
- The authorization applies to banks’ operating subsidiaries and permits institutions running nodes to receive network fees and hold them for an appropriate period as part of that activity.
- The clarification enables practical on‑chain operations such as custody transfers and settlement without broad speculative exposure, reducing reliance on third‑party fee providers and supporting thorough pre‑production testing.