By CBL Research · The Teller · 4 September 2026 · 4 min read
OpenReserve got a headline on Wednesday that most crypto companies would trade a year of runway for. The Office of the Comptroller of the Currency, the regulator that charters national banks in the United States, gave it preliminary conditional approval to organize a full-service national bank. Andreessen Horowitz led a $25 million seed round. CoinDesk, The Block and Bloomberg all covered it.
None of that means you can bank there. Not this year, and possibly not next year either. Here is what the approval means, what it does not mean, and how to read the next one of these, because there will be a next one.
Most crypto companies that have gone to the OCC since late 2025 asked for a national trust bank charter. A trust charter lets a company hold assets, settle trades and act as a custodian under federal supervision. It does not let the company take deposits or make loans. Circle, Ripple, Paxos, BitGo, Fidelity Digital Assets, Crypto.com and Stripe's Bridge all went this route. For a stablecoin issuer or a custodian, it is the right tool. For someone who wants a current account, it changes nothing.
OpenReserve asked for the other thing: a full national bank charter. That is the same licence Chase and Wells Fargo hold. It allows deposits, lending, payments and treasury services. It also brings the full weight of bank supervision, capital rules and FDIC insurance. Very few crypto companies have tried this. Anchorage held the only crypto-native federal charter for four years. Since 2025 the OCC has received 40 applications for new banks of all kinds and approved 21, and most of the crypto ones were trust charters. Full bank approvals in 2026 have gone to Nubank, Mercury, Upstart and, on the same day as OpenReserve, Revolut.
It means the OCC read the business plan and did not say no. That is the whole of it. The regulator's own letter says the approval is preliminary and conditional, that it is not an endorsement of the technology or the business model, and that the bank cannot open until every preopening requirement is met.
For OpenReserve the conditions are public. It must raise at least $210 million in paid-in capital, after subtracting what it has already spent on organizing. It must keep a Tier 1 leverage ratio of at least 12% for its first three years, which is a much thicker capital cushion than an established bank carries. It must get deposit insurance from the FDIC, which is a separate application to a separate agency. It must apply for Federal Reserve Bank stock. It must give the OCC 60 days notice before opening, and then pass a preopening examination that covers operations, governance, compliance and technology.
There are two clocks. The capital has to arrive within 12 months. The bank has to open within 18 months. Miss either one and the approval expires.
It does not mean the bank exists. OpenReserve is a company that has permission to try to build a bank. The $25 million it raised is not the $210 million it needs. The stablecoin it has talked about, ReserveUSD, needs its own subsidiary and its own filing, and the OCC letter notes that filing has not been made.
It also does not mean a retail product is coming. OpenReserve describes its customers as institutions, corporate treasurers and financial firms. Nothing on its site or in its filings mentions an account for an individual. If you have been debanked over crypto and you read this week's headlines as a way out, it is not one. Not yet.
There will be more of these. When you see "conditional approval" in a headline, ask three questions. Is it a trust charter or a full bank charter? Trust charters do not take deposits. Has the FDIC signed off? Without deposit insurance a bank cannot open. And has the company raised the capital in the OCC letter? The number is always public.
Circle is the only crypto company so far that has gone the full distance from conditional to final approval, and that took seven months for a trust charter. A full bank charter with a stablecoin subsidiary attached is a longer road.
We have added OpenReserve to the list as a bank in organization. It has no CBL Score, because there is nothing to score. It carries a Watch tag, for the reasons above. When it opens, we will score it like everyone else.
Read the OpenReserve profile →Sources: OCC public file on OpenReserve Bank (occ.treas.gov). OpenReserve announcement, Business Wire, 3 September 2026. The Block, 4 September 2026. CoinDesk, 3 September 2026. Davis Wright Tremaine, "OCC's Recent Charter Approvals Signal Momentum for Digital-Asset Bank Charters", 4 August 2026. Steptoe, "OCC Conditionally Approves Five National Trust Bank Charter Applications", 15 December 2025.