Regulatory Alerts2025-03-07 | Interpretive Letter 1183Added
Interpretive Letter 1183 — Reaffirmation of Permissible Crypto-Asset Activities and Rescission of Letter 1179
The Office of the Comptroller of the Currency rescinds Interpretive Letter 1179, which previously outlined a supervisory non-objection process for national banks and federal savings associations seeking to engage in specific crypto-asset activities. The letter reaffirms that crypto-asset custody, holding deposits serving as reserves backing stablecoins, and the use of distributed ledger technology and stablecoins to facilitate permissible payments activities remain permissible for these entities. These activities are now examined as part of the OCC's ongoing supervisory process rather than through the prior non-objection framework.
Interpretive Letter 1183 March 2025 OCC Letter Addressing Certain Crypto-Asset Activities March 7, 2025 This letter rescinds Interpretive Letter 1179 (November 18, 2021). This letter also reaffirms that the crypto-asset custody, distributed ledger, and stablecoin activities (hereafter, “crypto-asset activities”) discussed in prior letters are permissible. Specifically, the OCC issued three interpretive letters in 2020 and early 2021 addressing whether it is permissible for national banks and federal savings associations (collectively, “banks”) to engage in crypto-asset activities. These interpretive letters are: • OCC Interpretive Letter 1170 (July 22, 2020), addressing whether banks may provide crypto-asset custody services; • OCC Interpretive Letter 1172 (September 21, 2020), addressing whether banks may hold dollar deposits serving as reserves backing stablecoins in certain circumstances; and • OCC Interpretive Letter 1174 (January 4, 2021), addressing whether banks may (1) act as nodes on an independent node verification network (i.e., a distributed ledger) to verify customer payments and (2) engage in certain stablecoin activities to facilitate payment transactions on a distributed ledger. Since the issuance of Interpretive Letter 1179,1 OCC staff have continued to develop knowledge and expertise regarding crypto-asset activities. Based on this supervisory experience, the OCC has determined that Interpretive Letter 1179 is no longer necessary. This rescission is intended to reduce burden, encourage responsible innovation, and enhance transparency. The rescission will also ensure that bank activities will be treated consistently, regardless of the underlying technology. The OCC will examine the activities described in Interpretive Letters 1170, 1172, and 1174 as part of its ongoing supervisory process. As with any activity, banks must conduct all crypto-asset activities in a safe, sound, and fair manner and in compliance with applicable law. New activities should be developed and implemented consistent with sound risk management practices and align with banks’ overall business plans and strategies. /s/ Rodney E. Hood Acting Comptroller of the Currency 1 Interpretive Letter 1179 outlined a supervisory nonobjection process for banks that seek to engage in the activities addressed in Interpretive Letters 1170, 1172, or 1174.