A16z-Backed OpenReserve Wins OCC Approval to Charter Full-Service National Bank
Key Takeaways
- •The OCC granted OpenReserve preliminary conditional approval on September 2 for a full-service national bank charter, after a review of just under five months.
- •OpenReserve must raise at least $210 million in paid-in capital by roughly September 2027, open by March 2028, and hold a Tier 1 leverage ratio of at least 12% for its first three years.
- •A full national bank charter would let OpenReserve take deposits and lend, unlike the national trust charters held by Coinbase, Circle, Ripple, Paxos, and BitGo.
- •OpenReserve plans a separate wholly owned subsidiary to issue reserve-backed US dollar stablecoins, which has not yet filed with the OCC and must comply with the GENIUS Act.
- •The OCC also granted Revolut preliminary conditional approval this week, and critics including Sen. Elizabeth Warren have challenged the pace and legality of the agency's crypto charter approvals.

OpenReserve Bank, a blockchain-native fintech startup backed by Andreessen Horowitz and other major venture investors, has received preliminary conditional approval from the Office of the Comptroller of the Currency (OCC) to charter a full-service national bank in Salt Lake City, Utah. If it clears final approval, the move would place a blockchain-native firm among the small number of companies allowed to take deposits and lend under federal banking law—a step beyond what most crypto-focused chartered institutions have achieved to date.
The approval was granted on September 2, concluding a review that lasted just under five months after OpenReserve filed its application on April 13, according to the OCC's decision letter. The roughly five-month turnaround is notable given that prior OCC charter applications from fintech firms, such as payments companies pursuing national trust or bank charters, have in past years taken considerably longer or been withdrawn amid changing regulatory stances.
Capital and Leverage Requirements
The approval carries specific conditions. OpenReserve must raise at least $210 million in initial paid-in capital, net of organizational costs, and maintain a Tier 1 leverage ratio of at least 12% through its first three years of operation. The company has 12 months to raise the capital and 18 months to open; missing either deadline causes the approval to expire.
The required 12% leverage ratio is well above the 5% minimum federal regulators use to classify a bank as "well capitalized," a buffer that de novo banks are frequently held to because new institutions carry unproven risk profiles and no operating history.
In practical terms, OpenReserve now has until September 2027 to raise the $210 million and until March 2028 to open for business.
A Deliberately Different Charter Path
OpenReserve was incubated through a $25 million seed round led by a16z crypto, with Coinbase Ventures, Jump Capital, and Wintermute Ventures among the other investors. The company positions itself as an "always-on" bank—offering continuous, blockchain-based settlement instead of the batch-processing rails, such as ACH and wire transfers, that traditional banks rely on. ACH and wire transfers settle on fixed schedules—often with cutoff times and, in the case of wires, business-hours processing—whereas blockchain settlement can occur around the clock.
Diwakar Choubey, who co-founded OpenReserve with Richard Correia after running MoneyLion, said the choice of the harder full-service charter path—rather than the national trust charter most "crypto banks" have pursued—was intentional.
"We chose the national bank path deliberately," he said in a statement announcing the approval.
That decision separates OpenReserve from most of its crypto-charter peers. Coinbase, Circle, Ripple, Paxos, and BitGo all obtained national trust charters, which permit custody and fiduciary work but block deposit-taking and lending. A full national bank charter would allow OpenReserve to do both once it clears final approval. Full-service charters also bring deposit insurance eligibility through the FDIC and access to federal payment systems such as the Fedwire Funds Service, subject to the applicable applications and memberships.
Business Plan and Stablecoin Ambitions
OpenReserve's business plan centers on tokenized deposits, treasury management, foreign correspondent banking, and a banking-as-a-service platform for institutional clients. The company also intends to establish a separate, wholly owned subsidiary to issue and redeem U.S. dollar-denominated, reserve-backed stablecoins.
That subsidiary has not yet filed its own application with the OCC, and any stablecoin activity will have to comply with the GENIUS Act—the U.S. federal law governing stablecoin operations that went into effect in July last year. The GENIUS Act requires stablecoin issuers to meet reserve, disclosure, and licensing requirements, which is a key reason the stablecoin subsidiary would need its own regulatory pathway rather than operating under the bank charter alone.
A Broader OCC Push—and Pushback
OpenReserve was not the only recipient of such an approval this week. The OCC also granted British fintech Revolut preliminary conditional approval for a national bank based in Connecticut, part of what Comptroller Jonathan Gould has described as an effort to bring firms working on novel technology into the federally supervised banking system. Revolut had earlier pursued and withdrawn a US banking charter application during the previous administration, making this approval a second attempt at US banking licensure.
The pace has drawn criticism. Sen. Elizabeth Warren argued in May that a string of OCC crypto trust-bank approvals violated the National Bank Act, writing that the firms "look like crypto banks, not trust companies." The OCC nonetheless approved a national trust charter for the Trump-linked World Liberty stablecoin venture that August.
What happens next for OpenReserve hinges on meeting its capital-raising deadline and receiving final OCC approval, while the broader debate over the OCC's chartering pace—and any legal or legislative challenges to it—continues in Washington.