Regulatory Alerts2026-05-12 | Interpretive Letter 1192Added
Interpretive Letter 1192 — Applicability of State Money Transmitter Licensing Requirements
The OCC confirms that the National Bank Act preempts state money transmitter licensing requirements for Fidelity Digital Assets, National Association, allowing the bank to conduct federally authorized activities nationwide without holding a state license. This preemption applies because state licensing conditions prevent or significantly interfere with the bank's exercise of its federally authorized powers and are fundamentally inconsistent with the OCC's exclusive visitorial authority under 12 U.S.C. § 484. The OCC states that this conclusion applies to any similar state money transmitter licensing requirements that purport to apply to the bank.
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