OpenReserve Bank has won preliminary conditional approval from the Office of the Comptroller of the Currency to pursue a de novo national bank charter, placing its planned mix of traditional banking, digital-asset custody and tokenized deposit services under a federal banking framework if it can satisfy demanding preopening conditions.
The OCC’s conditional approval requires OpenReserve to raise at least $210 million in initial paid-in capital after organizational and preopening costs. The proposed bank must also maintain a Tier 1 leverage ratio of at least 12% during its first three years, according to the OCC letter issued Wednesday.
Those requirements give the agency a substantial financial cushion before OpenReserve can begin serving customers. A Tier 1 leverage ratio measures core capital against total assets, without adjusting for risk weightings. The 12% threshold exceeds the minimum applied to many established banks and reflects the OCC’s caution toward a new institution planning services across payments, custody and dollar-linked digital assets.
OpenReserve cannot yet operate as a bank. It must meet the OCC’s remaining preopening requirements, receive final approval, obtain deposit insurance from the Federal Deposit Insurance Corporation and apply for stock in its regional Federal Reserve Bank.
A full-service bank proposal with tokenized deposits
OpenReserve was founded in 2025 by Diwakar Choubey and Richard Correia. Its charter application describes a proposed full-service national bank offering deposit accounts, lending, payments and treasury services, foreign correspondent banking, digital asset custody and tokenized deposit products.
Tokenized deposits generally represent bank deposit liabilities on a blockchain or other distributed ledger. Unlike a conventional stablecoin, a tokenized deposit would be a claim on the issuing bank’s deposit account structure, potentially allowing deposits to move through programmable payment systems while remaining part of a regulated bank’s balance sheet.
The OCC letter also outlines OpenReserve’s intention to form a wholly owned subsidiary that would issue, custody, convert and facilitate payments involving U.S. dollar-denominated reserve-backed stablecoins. That subsidiary has not submitted an application to the OCC, the regulator said.
The distinction leaves the stablecoin operation outside the current approval. OpenReserve has received a conditional path toward a national bank charter; it has not received regulatory authorization for the proposed stablecoin subsidiary or for any particular dollar token.
That structure could allow the company to separate insured-bank functions from stablecoin issuance and related digital-asset services, subject to whatever approvals, capital arrangements and supervisory conditions regulators ultimately require. It also shows how firms seeking to combine banking and blockchain-based payments are increasingly designing entities around different regulatory perimeters rather than trying to house every activity in one institution.
Capital conditions set a high bar before launch
The $210 million capital requirement is far larger than OpenReserve’s previously disclosed $25 million seed financing round. Andreessen Horowitz’s a16z crypto led that round, with participation from Jump Capital, Acrew, Coinbase Ventures, Wintermute Ventures, Clocktower, Quona, AAF Management and Zero Knowledge Ventures.
Seed funding and regulatory capital serve different purposes. Venture financing supports hiring, technology, legal work and the lengthy process of building a new company, while paid-in bank capital is intended to absorb losses and support regulated operations. OpenReserve will therefore need considerably more financing before the OCC permits it to open.
The capital condition also limits the immediate market implications of the announcement. The OCC’s preliminary decision offers OpenReserve a route into federal banking, but the project remains dependent on fundraising, operational readiness, deposit insurance and final supervisory signoff. Each step can introduce new conditions or delays.
Foreign correspondent banking in the proposal could add another layer of compliance expectations. Correspondent services allow banks to provide payment and account infrastructure to other financial institutions, often across borders. A bank combining that business with custody and tokenized deposits would need robust controls for sanctions compliance, anti-money-laundering obligations, cybersecurity and the segregation of customer assets.
OCC charter activity expands under Jonathan Gould
OpenReserve’s approval arrives during an active period for the OCC’s chartering office under Comptroller Jonathan Gould. The OCC has received 40 de novo charter applications since 2025 and conditionally approved 21, according to figures provided in the agency’s action.
A de novo charter is issued to a newly formed bank rather than an existing institution converting from another charter. Such applications require regulators to assess the organizers, business model, governance, capital plan, risk controls and operational systems before a bank opens its doors.
The agency has separately issued conditional approvals for national trust bank charters to crypto-focused firms including Paxos, BitGo, Ripple and Circle. Trust bank charters generally support fiduciary, custody and related activities but do not necessarily permit the same deposit-taking and lending model proposed by OpenReserve.
Revolut also received conditional approval Wednesday, while the Trump-backed World Liberty Trust Company received approval weeks earlier. The growing number of decisions has made the OCC a central federal venue for digital-asset firms seeking a more direct relationship with bank supervision.
Scrutiny over the limits of crypto bank charters
The OCC’s approach has drawn criticism from some lawmakers. In May, Senator Elizabeth Warren raised concerns over the agency’s handling of national trust bank charters for crypto firms, citing limits in the National Bank Act on activities national banks may conduct. Her criticism referred to applications or approvals involving Ripple, Circle, Paxos, Fidelity, BitGo and Coinbase.
That debate is likely to continue as companies pursue charters that cover custody, payment infrastructure and tokenized financial products. Federal chartering can bring firms into a system of examinations, capital standards and formal governance obligations, but it also forces regulators to define how longstanding banking rules apply to new forms of digital money.
For OpenReserve, the immediate test is practical rather than symbolic: raise the capital demanded by the OCC, complete its preopening program and obtain FDIC insurance. If it clears those stages, its launch would add a federally chartered, full-service banking model to the small but growing set of financial institutions built around both conventional deposits and blockchain-based payment tools.
Curious how tokenized banking fits into broader regulation? Explore our guide on crypto regulation in the US next.
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