OCC Confirms Bank Authority to Hold Crypto-Assets as Principal for Paying Network Fees

On November 18, the OCC issued Interpretive Letter 1186 confirming that a national bank may, as an activity incidental to the business of banking, pay crypto-asset network fees to support otherwise permissible banking activities. The letter also states that a bank may hold, as principal, limited amounts of crypto-assets on its balance sheet when needed to cover these fees. In addition, the OCC confirmed that banks may hold small quantities of crypto-assets as principal for purposes of testing…
By: Sheppard Mullin Richter & Hampton LLP