OCC gives OpenReserve a conditional US national bank charter

The Office of the Comptroller of the Currency granted preliminary conditional approval to charter OpenReserve Bank, National Association, a proposed full-service insured national bank in Salt Lake City, Utah, with no branches. The letter is OCC Corporate Decision 1389, dated 2 September 2026, under control numbers 2026-Charter-345612 and 2026-Waiver-346445, proposed charter number 27203.

This is a first-step charter letter, not a live US bank, not FDIC insurance, and not final authorization to open. The OCC says it may modify, suspend, or rescind the approval until those preopening requirements are met. The bank still has to apply for Federal Reserve Bank stock under 12 USC 222 and obtain FDIC deposit insurance.

Organizers filed on 13 April 2026 under 12 USC 21 to 27 and 12 CFR 5.20. The plan covers deposit and lending, including tokenized capabilities across deposit products, plus payments and treasury, digital asset services, foreign correspondent banking, and a banking-as-a-service platform. Nonfiduciary digital-asset custody is treated as bank-permissible, citing prior OCC letters.

The capital floors are the part most one-line takes skip. Initial paid-in capital, net of organizational and preopening expenses, must be no less than $210 million. The bank must hold a Tier 1 leverage ratio of no less than 12.0 percent through the first three years of operation. If that capital is not raised within 12 months, or if the bank is not open within 18 months of this approval, the approval expires.

The organizers also plan a wholly owned stablecoin subsidiary for issuance, custody, conversion, and payment of USD reserve-backed stablecoins. That subsidiary application has not been filed. Any such activity must conform to the GENIUS Act (12 USC 5901 et seq.) as applicable, which the OCC listed as a condition.

The OCC granted residency waivers for all seven proposed directors. The same supervisor issued a parallel first-step letter the same week for Revolut Bank US. Tokenized deposit and custody plans sit next to South Korea's 2027 tokenized-securities roadmap and the SEC's transfer-agent rewrite. Large official-sector books are also moving, including Norges Bank Investment Management's plan to cut Treasury holdings.

US counsel, correspondent banks, and anyone pitching OpenReserve as already chartered should treat this as a clocked pre-open file. Watch the $210 million raise and the 12-month capital and 18-month open deadlines, and keep it off the insured-US-national-bank list until FDIC, Fed stock, and final OCC approval land.