OCC confirmed banks may hold crypto for blockchain network fees

The Office of the Comptroller of the Currency confirmed on November 18, 2025 that national banks may hold limited amounts of crypto-assets on their own balance sheets when those assets are needed to pay blockchain network fees for otherwise permissible banking activities.

Interpretive Letter 1186 also permitted a national bank to hold crypto-assets needed to test an otherwise permissible crypto-related platform, whether the bank developed that system internally or acquired it from a third party. The decision mattered because it addressed a practical obstacle between legal authority to offer blockchain services and the ability to operate those services directly.

What the OCC authorized

Some blockchains require transaction fees to be paid in the network’s native asset. The OCC used Ethereum as an example: transactions involving tokens or smart contracts operating on Ethereum still require fees denominated in ETH. A bank without an operational ETH balance could have to buy ETH immediately before a transaction or rely on another company to pay the fee.

The letter concluded that a national bank may instead hold, as principal, the amount of crypto-assets needed for network fees it reasonably expects to incur. “As principal” is important here. It means the bank owns the operational balance and records it on its own balance sheet, rather than merely safeguarding assets belonging to a customer.

The authority also applied to a national bank’s operating subsidiaries. The OCC reasoned that paying network fees could be incidental to permissible activities such as crypto custody, customer-directed transactions, stablecoin payments or participation as a node on a distributed-ledger network.

Testing received separate treatment

The OCC separately recognized that meaningful platform testing may require actual crypto-assets. Banks could use those holdings to test transactions, controls, compliance functions and other system capabilities before or during operation.

Requiring a third party to supply assets for every test could increase costs and introduce operational or counterparty dependencies, the letter said. The regulator therefore treated limited testing balances as incidental to operating an otherwise permissible banking platform—not as a separate investment activity.

Why the distinction mattered

Earlier OCC interpretations had already recognized bank authority involving crypto custody, certain stablecoin activities, distributed-ledger payment networks and customer-directed execution. On March 7, 2025, the agency also removed a special supervisory non-objection process that had applied to several previously recognized crypto activities. On May 7, it confirmed that banks could outsource permissible custody and execution services under appropriate third-party risk management.

The November 18 letter filled a narrower operational gap. Permission to transfer or custody blockchain-based assets can be difficult to use if the bank cannot maintain the native asset required to submit transactions. Interpretive Letter 1186 connected the underlying banking authority with the mechanics of public blockchain networks.

That was institutionally significant, but its scope was limited. The letter did not grant national banks unrestricted authority to accumulate bitcoin, ether or other crypto-assets for price appreciation. It addressed amounts necessary for reasonably foreseeable network fees and platform testing under the requesting bank’s stated facts and controls.

Risk controls remained mandatory

The unnamed requesting bank represented that it would assess technical design, operational, market, liquidity and compliance risks. The OCC said the activities remained subject to safe-and-sound banking requirements, applicable law and continuing supervision.

The decision also did not establish that any bank had begun holding a particular asset, disclose an approved balance limit or determine the accounting and capital treatment for every implementation. No event-day adoption total or market-price effect was documented.

What the November 18 record established was legal and operational: a national bank did not necessarily need an outside fee provider whenever a permissible blockchain activity required a native crypto-asset. Whether banks would use that authority—and how supervisors would evaluate individual controls—remained an implementation question.