Regulatory Alerts2025-11-18 | Interpretive Letter 1186Added
Interpretive Letter 1186 — Authority of national banks to hold crypto-assets as principal and pay crypto-asset network fees as incidental to a permissible banking activity
The Office of the Comptroller of the Currency confirms that national banks may hold crypto-assets as principal on their balance sheets to pay network fees for reasonably foreseeable transactions and for testing crypto-asset platforms. This authority applies to activities incidental to permissible banking functions, such as custody services, provided the bank maintains de minimis holdings relative to capital and conducts risk and compliance assessments. The determination relies on the activities facilitating the production or delivery of banking products and improving operational efficiency under 12 U.S.C. 24(Seventh) and 12 C.F.R. 7.1000(d)(1).
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