On September 2, the OCC granted preliminary conditional approval for a de novo full-service national bank headquartered in Utah that plans to offer tokenized deposit products, digital asset custody services in a nonfiduciary capacity, payments and treasury services, foreign correspondent banking, and a banking-as-a-service platform. The proposed bank also plans to form a wholly owned subsidiary to issue, custody, convert, and facilitate payments of U.S. dollar-denominated reserve-backed stablecoins, though the subsidiary application has not yet been filed. The proposed bank will also permit customers to pay cross-border remittances using digital assets, including stablecoins. The OCC confirmed that cryptocurrency custody services are permissible as part of or incidental to the business of banking and that national banks may hold digital assets on balance sheet as necessary to pay network transaction fees. The bank’s initial paid-in capital, net of organizational and preopening expenses, must be no less than $210 million.

The approval is subject to several conditions, including that the bank must conform its activities to the GENIUS Act and any implementing regulations, with compliance to be determined “in the sole discretion of the OCC.” The bank must provide the OCC’s Specialty Assets Supervisory Office at least 60 days’ prior written notice of any significant deviation from its business plan and obtain a written determination of no objection before implementing any such change, a condition that remains in effect during the in-organization period and the first three years of operation. The OCC requires the bank to maintain a tier 1 leverage ratio of no less than 12 percent throughout its first three years and to obtain a prior OCC letter of no objection before appointing any senior executive officer or director during the same period.