The Office of the Comptroller of the Currency has granted preliminary conditional approval to OpenReserve Bank, N.A. for a de novo full-service national bank charter in Salt Lake City, Utah. It is a significant regulatory milestone, though one that arrives with a heavy price tag and a long runway before the first customer walks through the door.
For years, the crypto-native playbook for banking has been the trust bank charter. Firms like Circle, Ripple, Paxos, BitGo, and Fidelity have operated under these limited umbrellas, which allow for custody but strictly prohibit deposit-taking and lending. OpenReserve is attempting something structurally different. By securing a full-service national bank charter, the firm gains the ability to hold deposits, issue loans, and facilitate stablecoin issuance – a trifecta that trust banks have long coveted but never reached.
The firm, led by co-founders Dee Choubey – who previously founded MoneyLion – and Rick Correia, a veteran of Merrill Lynch and Citadel, is positioning itself to solve a specific structural friction: the Fedwire dead zone. The Federal Reserve’s payment rails go offline for roughly twenty-two hours a day, including nights, weekends, and holidays. OpenReserve claims that stablecoin rails settled approximately $33 trillion in 2025, and it intends to capture a portion of that volume by offering 24/7 atomic on-chain settlement during the hours when traditional banking infrastructure goes dark.
The regulatory path, though, is far from complete. The company’s plan to issue a stablecoin through a wholly-owned subsidiary called ReserveUSD requires a separate, distinct OCC approval that has not yet been filed. The bank faces stringent capital requirements: $210 million in initial paid-in capital and a 12% Tier 1 leverage ratio for the first three years – double the standard 5% hurdle for traditional banks. OpenReserve has until September 2027 to close its capital raise, with a target to open for business by March 2028.
OpenReserve’s approach also diverges from the distribution-first model recently adopted by Revolut, which received its own conditional national bank charter from the OCC this same week. While Revolut separates stablecoin issuance from distribution – offloading the token to a third-party issuer – OpenReserve is building a vertically integrated stack that includes tokenized deposits, treasury management, and banking-as-a-service for institutional clients. It is the difference between renting the pipes and owning them.
The timing of this approval is not coincidental. Comptroller Jonathan Gould has noted that of forty pending bank charter applications, twenty-three involve digital assets. This wave of activity is occurring against the backdrop of the GENIUS Act, which is expected to see a final rule in November 2026, with enforcement beginning January 18, 2027. The industry is currently waiting on seven agencies that missed the initial July 18 rulemaking deadline.
Backed by a $25 million seed round led by a16z crypto – with participation from Coinbase Ventures, Jump Capital, Wintermute Ventures, Acrew Capital, Quona Capital, and Clocktower Ventures – OpenReserve has the institutional backing to attempt this build. But the transition from a preliminary approval to a functioning, fully capitalized national bank is a multi-year gauntlet. The charter is a license to compete; the real work has only just begun.