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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 crypto-asset platforms.
The OCC framed these activities as a modern extension of established bank powers, emphasizing that limited principal holdings can support operational efficiency and customer transactions when tied to foreseeable network-fee needs. The agency noted that these activities must remain de minimis, risk-controlled, and integrated into existing compliance and oversight programs.
Putting It Into Practice: Federal regulators continue to clarify the scope of permissible digital-asset activities (previously discussed here and here). Banks considering distributed-ledger integrations should reassess network-fee dependencies, confirm that any crypto-asset holdings remain de minimis and purpose-driven, and update internal controls and governance frameworks accordingly. Financial institutions should continue monitoring federal and state supervisory developments as digital-asset requirements evolve.
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