OpenReserve and Revolut Win Preliminary OCC Approval for National Bank Charters

The Office of the Comptroller of the Currency granted preliminary national bank charter approval to both OpenReserve and Revolut on September 4, marking the most direct regulatory endorsement yet of crypto-native firms operating inside the federally chartered banking system.

OpenReserve, backed by Andreessen Horowitz, is building a bank centered on onchain settlement. Revolut, the London-based fintech with over 50 million customers globally, received its approval in parallel. Both companies intend to offer cryptocurrency and stablecoin-related services as core parts of their banking operations.

The more consequential detail is which charter path OpenReserve chose. Most crypto-adjacent firms pursuing federal banking licenses have opted for the trust-bank structure, a narrower regulatory pathway that limits deposit-taking and lending activity. OpenReserve went for a full national bank charter instead. That distinction matters: a full charter enables FDIC-insured deposits and conventional lending alongside stablecoin issuance, putting OpenReserve in the same regulatory category as JPMorgan or Wells Fargo rather than the more restricted tier occupied by firms like Anchorage Digital, which received a national trust charter in 2021.

Preliminary approval is not a green light to open for business. OpenReserve must still raise $210 million in capital and clear three additional federal authorizations before the OCC grants final approval. Those conditions represent a substantial compliance runway, and regulators retain the authority to impose restrictions on stablecoin issuance or crypto service offerings during that process.

The signal from the OCC carries weight independent of what happens next for either company. The agency's willingness to grant preliminary approvals to two firms with explicit crypto mandates under a full national charter framework suggests a meaningful shift in federal banking regulators' posture toward digital assets. For years, crypto firms seeking banking infrastructure in the United States faced a patchwork of state-level options, foreign jurisdictions, or the limited trust-bank route. A full national charter, if finalized, would give OpenReserve preemption over state banking laws and access to the Federal Reserve's payment systems.

Revolut's path carries different dynamics. The company has operated in the United States under a money transmitter license structure while its U.S. bank charter application worked through the system. Preliminary OCC approval brings it closer to offering FDIC-insured accounts to American customers, a capability that would sharpen its competitive position against neobanks like Chime and SoFi, both of which partner with chartered banks rather than holding their own charters. Revolut's stablecoin ambitions, including its euro-denominated EURR token, could also benefit from the regulatory clarity a federal charter provides.

The broader context is a regulatory environment that has shifted considerably since 2022. The collapse of crypto-friendly banks Silvergate and Signature in early 2023 triggered a period of aggressive caution from federal banking regulators, with the Federal Reserve and OCC both issuing guidance that effectively discouraged chartered banks from taking on significant crypto exposure. That guidance has since been walked back or softened under subsequent administrations, and the OCC's action this week reflects where the pendulum now sits.

Competition from established institutions will test whether regulatory access translates to market share. Major banks including JPMorgan and Bank of America have accelerated their own digital asset and tokenization efforts over the past two years. OpenReserve and Revolut will be entering a federally chartered banking landscape that is no longer ignoring crypto, which changes the calculus for what differentiation actually means.

The OCC has not published a formal timeline for when final approvals might follow for either applicant. Both companies will need to satisfy their remaining conditions before the charter becomes operational.