Crypto Bank OpenReserve Wins Full OCC National Charter, Targets Fedwire Dead Zone

OpenReserve Bank, a blockchain-native startup backed by Andreessen Horowitz and a roster of crypto-industry investors, received preliminary conditional approval from the Office of the Comptroller of the Currency on September 3 to establish a full-service national bank — a milestone that stands apart from the wave of trust charters that have defined the OCC’s crypto-approval spree, and one that is specifically designed to keep money moving during the hours when the U.S. banking system goes dark. The approval arrives as the OCC, under Comptroller Jonathan Gould, simultaneously granted a similar nod to Revolut, underscoring that the agency is processing crypto-adjacent bank applications in volume rather than one at a time.

What Makes OpenReserve’s Charter Different From Every Other Crypto Approval

Most of the attention surrounding the OCC’s crypto-chartering push has focused on national trust bank charters — limited-purpose licenses that allow companies like Circle, Ripple, Coinbase, and Paxos to provide custody and settlement services under federal supervision. Those charters are significant, but they carry a hard constraint: they cannot accept insured deposits or make conventional loans. They give crypto firms a federal license; they do not make those firms banks in the full consumer-facing sense. Sources confirm the December 2025 trust charter approvals were the first time the regulator approved multiple crypto-native firms simultaneously.

OpenReserve made a different bet. Rather than applying for a trust charter, the company filed for a de novo full national bank charter — the same category that governs JPMorgan, Wells Fargo, and every community bank in the country. The practical difference is substantial. A full national bank can accept FDIC-insured deposits — protecting consumers up to $250,000 per account — offer conventional lending, and access the Federal Reserve’s payment infrastructure directly once it receives Fed membership. A trust charter holder can do none of those things.

Sen. Elizabeth Warren formally challenged the OCC in May on its trust charter approvals, arguing the firms “look like crypto banks, not trust companies,” and questioning whether the National Bank Act authorizes limited-purpose charters for crypto activities. Whatever the legal outcome of that challenge, it applies specifically to the trust charter category. OpenReserve, with its full national charter and requirement to obtain FDIC deposit insurance, occupies structurally different legal ground — one whose authority traces to banking law that has not been seriously contested for more than 160 years. The Warren letter is documented on the Senate Banking Committee website.

How OpenReserve’s Blockchain Core Actually Works: Why Fedwire Matters

The American banking settlement system has a fundamental engineering gap that rarely comes up in consumer finance but matters enormously to anyone who needs to move large amounts of money in real time: the Federal Reserve’s Fedwire Funds Service, the system that enables final, irrevocable settlement between banks, operates on a weekday-only business schedule. On nights, weekends, and federal holidays, Fedwire goes offline. No bank-to-bank real-time gross settlement is possible during those windows. The Fed’s FedNow service, launched in July 2023, extended ACH-like transfers closer to around-the-clock availability, but without Fedwire’s large-value, high-finality capabilities.

OpenReserve is building what its founders describe as a programmable core ledger with native onchain settlement — meaning the bank’s internal settlement infrastructure runs on a distributed ledger rather than on conventional batch-processing rails. The key architectural difference: blockchain-based settlement is atomic (every transaction either completes entirely or does not occur at all), irreversible once finalized, and available 24 hours a day, 7 days a week, 365 days a year. It does not have a closing bell.

For comparison: the Automated Clearing House network, which processes standard bank transfers, batches transactions and settles them at scheduled intervals, with standard settlement taking one to three business days and costs of roughly $0.20 to $1.50 per transaction. Nacha’s 2025 annual report confirms the network processed 35.2 billion payments worth $93 trillion last year. Blockchain-based stablecoin rails settled $33 trillion in 2025 — 72 percent more than the previous year — at costs that can fall below $0.01 per transaction on modern chains. A federally chartered bank running on those rails would combine that settlement efficiency with the consumer protections of traditional banking for the first time.

There is an important distinction between what OpenReserve plans and what already exists in the market. Stablecoins like USDC and USDT are bearer instruments: claims on the entity that issued them, not on a bank. If a stablecoin issuer fails, holders face counterparty risk with no depositor protection. OpenReserve’s planned tokenized deposits would be on-chain representations of balances held at a nationally chartered, FDIC-insured bank — making them claims on OpenReserve directly, protected up to the statutory deposit insurance limit. This is the engineering architecture that the a16z crypto investment blog post captured when it described its investment rationale: “We need a bank that’s always on, always open, always available. A bank that never closes.”

The tradeoff OpenReserve is accepting for this architecture is visible in the OCC’s capital requirements. Standard well-capitalized banks must maintain a Tier 1 leverage ratio of 5 percent. The OCC is requiring OpenReserve to maintain a minimum 12 percent Tier 1 leverage ratio for its first three years of operation — more than twice the standard threshold. That elevated requirement reflects the regulatory reality that blockchain-native settlement introduces new categories of operational risk: smart contract vulnerabilities, cryptographic key management, and the technical capability to “freeze and burn” assets on demand as the GENIUS Act requires of stablecoin issuers. The higher capital cushion is how the OCC is pricing that risk while the technology matures. All requirements are detailed in the OCC’s decision letter for OpenReserve.

What OpenReserve Is Building

Founded in 2025 by Diwakar “Dee” Choubey — previously the co-founder and CEO of fintech lender MoneyLion — and Richard Correia, OpenReserve is designed to offer the full range of banking services alongside crypto-native infrastructure. Its product suite spans standard deposits, commercial and retail lending, treasury management, and payment services, combined with tokenized deposit capabilities, digital asset custody, and treasury payment services engineered to run continuously.

The company’s most ambitious near-term objective is a wholly owned subsidiary called ReserveUSD — designed to issue, hold, convert, and process U.S. dollar-backed stablecoins compliant with the GENIUS Act framework, the federal stablecoin law Trump signed in July 2025. That subsidiary application has not yet been filed with the OCC; stablecoin issuance will require a separate approval process. OpenReserve’s main office will be in Salt Lake City, Utah, though the bank will operate entirely through digital channels with no retail branches.

Before OpenReserve can open its doors, it must raise at least $210 million in initial paid-in capital, net of organizational and pre-opening expenses, by September 2027 — twelve months from the approval date. It must also secure FDIC deposit insurance and obtain Federal Reserve membership. Banking operations must commence by March 2028. Miss either deadline, and the preliminary approval expires.

The company previously closed a $25 million seed round led by a16z crypto, with Jump Capital, Coinbase Ventures, Wintermute Ventures, Acrew, Clocktower, Quona, AAF Management, and Zero Knowledge Ventures also participating. That $25 million represents a fraction of the $210 million the OCC now requires, leaving a substantial fundraising gap the company will need to close before final approval is possible.

What the OCC’s Approval Pace Signals

OpenReserve’s approval completed in just under five months from application — a pace that reflects a fundamental shift in how the OCC under Comptroller Gould approaches new bank formation. The agency received 40 de novo charter applications since 2025 and has approved 21, while denying two. The OCC’s August 2026 press release documents this historic chartering surge. For context: between 2011 and 2024, the OCC averaged fewer than four de novo applications per year, and in some years received none at all. That history is detailed in Kaufman Rossin’s chartering revival analysis.

That history illuminates why the comparison to earlier applicants is instructive. Figure Technologies, a blockchain lending company, applied for a national bank charter in November 2020 and spent nearly three years navigating a more hostile regulatory environment before withdrawing its charter application in August 2023, never receiving final approval. The three-year timeline was not a slow path to approval — it was a three-year effort that ended without one. That regulatory climate has reversed entirely.

The same-day approvals for OpenReserve and Revolut — one a blockchain-native startup built around onchain settlement, the other a British fintech that has explicitly said it does not intend to hold digital assets on its balance sheet — underscore that the OCC is comfortable chartering across a wide spectrum of models rather than favoring any particular approach. Revolut’s lower capital requirement reflects its significantly more conservative crypto posture; OpenReserve’s steeper $210 million requirement reflects the risk premium the OCC is assigning to blockchain-native infrastructure.

The chartering wave has not gone unchallenged. The Bank Policy Institute, whose board includes JPMorgan CEO Jamie Dimon and Goldman Sachs CEO David Solomon, has weighed legal action against OCC charters, arguing the agency is reinterpreting federal licensing rules in ways that give crypto firms federal imprimatur without the full compliance obligations of traditional banks. The American Bankers Association formally asked the OCC in February 2026 to slow crypto charter approvals, citing the 2022 collapses of FTX and Celsius as examples of the risks novel business models can generate when they fail. The Conference of State Banking Supervisors has warned that trust-charter approvals amount to “Franken-charters” — regulatory structures assembled from legal components never designed to work together. The CSBS made this criticism in a formal comment letter to OCC in February 2026.

Again, these criticisms target the trust-charter framework specifically, not full national bank charters like OpenReserve’s. A full-service national bank operating under FDIC insurance applies for its charter under the same well-established legal authority that has governed American commercial banking since the National Bank Act of 1864. The legal questions being raised about the trust charter wave do not directly implicate that authority.

Does OpenReserve Still Need to Clear the Hard Part?

The preliminary conditional approval is exactly that: preliminary. The OCC’s decision letter gives OpenReserve a regulatory path, not a bank. The agency retains the authority to modify, suspend, or revoke the preliminary approval before OpenReserve opens for business. Final authorization depends on completing every pre-opening condition within the regulator’s deadlines.

The financing gap is real. Twenty-five million dollars against a $210 million floor means OpenReserve needs to raise roughly $185 million more before final approval — in a timeframe of twelve months. That is achievable for a company with the investor quality OpenReserve has assembled, but it is not guaranteed; the crypto and fintech VC environment remains selective even when favorable, and the OCC has already published its first denial letters, in July and August 2026, demonstrating that preliminary approval is not automatic confirmation of the final outcome. Both denials are discussed in Kaufman Rossin’s de novo chartering analysis.

The stablecoin subsidiary adds a separate approval track. OpenReserve’s planned ReserveUSD product will need to file a distinct application, comply fully with the GENIUS Act’s implementation framework — which requires coordinated rulemaking across five federal agencies — and clear all the conditions the OCC ultimately imposes. That process is measured in years, not months.

What OpenReserve has achieved is a seat at the table: federal recognition that a blockchain-native bank, built around continuous settlement infrastructure and GENIUS Act-compliant stablecoin issuance, is a permissible institution under the National Bank Act. If it closes its funding and clears pre-opening requirements, it would be among the very few blockchain-native firms to enter the U.S. banking perimeter not as a trust company or fintech licensee, but as a full nationally chartered bank — one designed to keep working through the hours when traditional settlement stops.

Frequently Asked Questions

What is the difference between a national bank charter and a national trust bank charter?

A full national bank charter — which OpenReserve received — allows the institution to accept FDIC-insured deposits, make conventional loans, and access the Federal Reserve’s payment infrastructure. A national trust bank charter is a limited-purpose license that allows companies to provide custody, settlement, and fiduciary services under federal oversight, but without the ability to take deposits or lend money. Most crypto firms that have received OCC approvals in 2025 and 2026, including Circle, Ripple, Coinbase, and Paxos, received trust charters. OpenReserve is applying for the fuller version of the license, which is subject to stricter capital requirements but carries consumer deposit protections that trust charters lack.

What is the “Fedwire dead zone” and why does OpenReserve want to fix it?

Fedwire is the Federal Reserve’s real-time gross settlement system — the infrastructure that enables final, irrevocable bank-to-bank money transfers. It operates during weekday business hours but goes offline on nights, weekends, and federal holidays. During those windows, no real-time final settlement is available through traditional banking channels, which can create delays for international treasury operations, crypto exchanges, and any institution that needs to move large amounts of money outside business hours. OpenReserve’s blockchain-native core settlement is designed to run continuously, eliminating that window. A federally chartered, FDIC-insured bank with 24/7 settlement capability does not yet exist in the U.S. banking system — OpenReserve is attempting to become the first.

What is a tokenized deposit, and how is it different from a stablecoin?

A stablecoin is a cryptocurrency issued by a private company and pegged to the U.S. dollar. If you hold USDC and Circle fails, you hold a claim on Circle — not on a bank, and not protected by FDIC insurance. A tokenized deposit is an on-chain representation of a balance at a federally insured bank. If OpenReserve opens and issues tokenized deposits, those would be claims on OpenReserve Bank — FDIC-insured up to $250,000 per depositor, the same protection that applies to a checking or savings account at any traditional national bank. The technical experience may look similar to holding a stablecoin, but the legal and insurance structure is fundamentally different.

Is OpenReserve open for business yet?

No. The OCC’s preliminary conditional approval is the beginning of a multi-step process. OpenReserve must raise at least $210 million in paid-in capital by September 2027, obtain FDIC deposit insurance, and clear a full pre-opening examination before receiving final authorization to operate. Banking operations must begin by March 2028. The OCC retains authority to modify or revoke the preliminary approval if any pre-opening requirement is not met. OpenReserve’s planned stablecoin subsidiary will require a separate application and approval process.