OpenReserve Receives Preliminary Conditional Approval from OCC
The Office of the Comptroller of the Currency (OCC) has granted preliminary conditional approval for the establishment of OpenReserve Bank, National Association, with its proposed headquarters in Salt Lake City, Utah, and no branches, under charter number 27203. The approval date is September 2, and the application was submitted on April 13 in accordance with the National Bank Act and 12 CFR 5.20, while also applying for deposit insurance from the Federal Deposit Insurance Corporation (FDIC).
The OCC specified that this is a preliminary conditional approval, and final opening must meet pre-opening conditions, understanding that the bank will purchase Federal Reserve Bank stock and obtain federal deposit insurance. Before final approval, the OCC may modify, suspend, or withdraw the approval. The residency requirement for seven proposed directors has been waived. Public documents position the bank as a full-service national bank aimed at native digital asset customers, integrating blockchain infrastructure with traditional lending and settlement, and planning to establish a wholly-owned subsidiary, ReserveUSD, to engage in stablecoin business related to the GENIUS Act. The official website also states that it has not solicited deposits, loans, or securities from the public. The affiliated broker OR Securities is a non-bank affiliate, with a pending application for new membership with FINRA.
The holding company OpenReserve Holdings has reported a Regulation D seed round to the SEC, targeting $25 million, with the first sale date on April 13, having raised approximately $24.0055 million from eleven accredited investors. AAF Management stated that it participated in this round, alongside a16z crypto, Jump Capital, Coinbase Ventures, Clocktower Ventures, and Quona Capital. Proposed CEO Diwakar Choubey is a co-founder of MoneyLion, and proposed President and COO Richard Correia has held operational roles at Merrill and Citadel. The founding team also includes heads of architecture, risk control, and technology.
Preliminary approvals generally require raising sufficient capital within twelve months and commencing operations within eighteen months, or the approval will expire. During the same period, the OCC has also processed several trust charters and full-service charters: trust charters for Circle and others have received conditional approval, while Erebor and Upstart are pursuing full-service paths; Wise's trust application and Bunq's new bank application were previously rejected. The interval from conditional approval to charter effectiveness for Circle was about seven months.
Who is buying and who is selling: The event is driven by the scarcity of federal full-service licenses, not by products already launched. Buyers are crypto institutions looking to invest in deposit-taking, Federal Reserve settlement, and their own lending rights; sellers are using the seed round to buy organizational time and pre-opening inspections. Beneficiaries are the founding teams that already hold conditional approvals, while those still stuck at state trust or uninsured channels are under pressure. Funds are moving from venture capital to statutory capital accounts, as the license itself cannot be used as deposits.
Source: Public Information
ABAB AI Insight
The OCC distinguishes between trust charters and full-service charters. Circle, Ripple, Paxos, BitGo, and Fidelity Digital Assets hold custodial and fiduciary obligations, cannot accept insured deposits, and cannot lend in their own name. OpenReserve is applying for a full-service national bank with FDIC insurance, in the same lane as Erebor and Upstart. Choubey aims to fill the gap of "on-chain settlement plus balance sheet lending" using MoneyLion's experience in consumer credit and alternative data.
The capital path involves first using the $25 million seed round to pay for legal fees, capital preparation, and the Salt Lake City licensing process, then using the conditional approval to secure a larger round and a Federal Reserve account. ReserveUSD is framed as a GENIUS Act compliant stablecoin, intending to integrate the bank's ledger and token issuance within the same holding structure. The logic of the Middle Eastern fund AAF is based on time zones: Abu Dhabi's business days do not overlap with U.S. banking days, requiring continuous capital that needs a license rather than a weekend-closed agency bank.
Comparative objects include Anchorage's long-term exclusive trust charter, Coinbase's conditional trust approval, and Circle's seven-month organizational period. The industry position reflects a shift for crypto companies from "finding a partner bank" to "becoming a bank" themselves, with control still resting on pre-opening inspections and deposit insurance decisions.
Structural changes are driven by regulatory shifts combined with industry chain restructuring. The mechanism is that the national bank charter shifts accountability from contractual counterparties to federal regulators, allowing institutional counterparties to recognize the finality of settlement; if a stablecoin subsidiary is established, the issuance reserves will directly fall within the insured deposit system, rather than being outsourced to a partner bank that can sever ties at any time.
ABAB News · Cognitive Laws
Trust charters are safes, while full-service charters are banks.
Conditional approvals buy organizational time, not operational opening.
Continuous capital competes not on on-chain speed, but on who can still be recognized as a bank over the weekend.