U.S. OCC Grants Conditional Approval for OpenReserve National Bank License in Salt Lake City, Utah
The U.S. Office of the Comptroller of the Currency (OCC) issued Company Decision No. 1389 on September 2, granting preliminary conditional approval to OpenReserve Bank, National Association, proposed to be established in Salt Lake City, Utah, under charter number 27203, as a full-service national bank application, rather than just a trust license.
The approval is based on the application materials and commitments, provided that the bank will purchase shares in the Federal Reserve Bank in accordance with regulations and apply for deposit insurance from the Federal Deposit Insurance Corporation (FDIC). Final authorization to open must meet all pre-opening conditions; prior to that, the OCC may modify, suspend, or withdraw the approval. On the same day, another decision conditionally approved Revolut's national bank application in Connecticut.
Founder Dee Choubey previously founded the consumer finance company MoneyLion, which was sold to Gen Digital for approximately $1.2 billion after going public in 2025. Co-founder Rick Correia has held operational leadership roles at Merrill and Citadel, and has worked with Choubey for nearly a decade. a16z crypto led a $25 million seed round, with follow-on investments from Jump Capital, Coinbase Ventures, and others. a16z describes it as a "bank that never closes," focusing on rebuilding the core system as a layered network to support 24/7 settlement, stablecoins, tokenized deposits, and on-chain capital markets.
The two stated in an a16z program that they aim to connect traditional banking operations and on-chain markets on the same balance sheet when both regulations and blockchain mature, and to turn idle assets like receivables into programmable collateral. The stablecoin initiative is named Reserve USD, promoted as being backed 1:1 by government bonds, discussing scenarios like large redemptions on Sunday afternoons that banks typically do not encounter. The sales side mentioned fronting bankers and institutional sales. This year, the OCC has conditionally approved several crypto-related trust licenses while rejecting some fintech applications; the director stated that it no longer pursues zero risk tolerance, with the standard being "reasonable chances of success."
Market mechanisms indicate that what is being bought is access to the federal balance sheet and deposit insurance eligibility, while what is being sold is a patchwork of state licenses that could lead to weekend shutdowns. Venture capital views the license progress as an infrastructure asset, with funds entering the new bank's capital in Salt Lake City and core systems, rather than creating another layer of unlicensed wallets. Beneficiaries are stablecoin and tokenized issuers that require 24/7 settlement counterparties; those under pressure are custodial banks that still settle on business days, and applicants who have not yet received FDIC approval—conditional approval does not equate to the ability to accept deposits.
Note: A legal letter has been sent to Skadden. Whether the bank can ultimately open depends on the progress of insurance and the Federal Reserve; the OCC has publicly reminded that this is a higher-risk wait.
Source: Public Information
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Describing the bank's core as "like a layered network" is packaging the license application as a system design. The real scarcity is not another stablecoin brand, but a national bank balance sheet that can settle on Sundays, access Federal Reserve accounts, and discuss deposit insurance. MoneyLion has been lending with alternative data for twelve years, still standing on the core from the 1970s; after selling to a security software group, the same founders are opening the next company directly at the OCC window. Trust licenses manage custody, while full-service licenses are necessary for deposit-taking and lending; the two are often mistakenly referred to as "bank licenses" in the market.
The capital path is secondary founders cashing out—crypto fund seed rounds—conditional federal approval. a16z invests in both technology and regulatory timelines, framing "why the U.S. capital markets matter" as a geopolitical product: USD stablecoins need to have U.S. banks as counterparties, rather than just circulating on overseas chains. If Reserve USD is realized, government bond collateral and bank deposits will compete for the same type of reserves; tokenized deposits will turn liabilities themselves into transferable tools. Fronting bankers indicate that clients are not retail app download numbers, but the demand from institutional funds outside business days.
Comparative examples include the trust routes of Circle, Paxos, and Ripple, as well as the conditional approval of Stripe's Bridge. In contrast, applications like Wise and bunq have been rejected. The industry phase has shifted from "crypto companies seeking banks" to "crypto founders applying to become banks themselves." The Chokepoint narrative in the previous cycle was the fear of loan cuts, while this cycle has transformed into a license competition after the window reopens.
Structural changes are regulatory changes. The mechanism is that whoever first assembles the core system, reserves, and insurance trio can provide the ultimate settlement asset for custodial deposits in the on-chain market. Conditional approval shifts the time value from product launch events to FDIC queuing; before opening, the narrative has already been priced like a bank, while cash is still consumed like a startup.
ABAB News · Cognitive Laws
Conditional approval sells the calendar, not deposit insurance
Describing the bank's core as a layered network still requires passing the OCC
A counterparty that can settle on weekends is scarcer than a new stablecoin brand