OpenReserve’s $210M Capital Test After Conditional OCC Nod

The Office of the Comptroller of the Currency granted OpenReserve Bank preliminary conditional approval on September 2 to charter a full-service national bank in Salt Lake City, Utah, opening a path toward deposit-taking and lending for the a16z-backed fintech – but the approval is conditional, not operational, and comes with a $210 million capital bill attached.

OpenReserve Gets Preliminary Approval for a Full-Service National Bank

The decision closes out a review of just under five months. OpenReserve filed its application on April 13, and the OCC signed off on September 2, according to the official decision letter.

The approval comes with specific numbers attached, not a blank check. OpenReserve must raise at least $210 million in initial paid-in capital, net of organizational costs, within 12 months, and it must maintain a Tier 1 leverage ratio of at least 12% through its first three years of operation.

Miss either deadline and the approval lapses. OpenReserve has until September 2027 to raise the capital and until March 2028 to open for business, and before it can take a single deposit it still has to clear the OCC’s pre-opening requirements and secure final approval.

A Blockchain-Native Bank Built for Onchain Settlement

OpenReserve is backed by a $25 million seed round led by a16z crypto, with Coinbase Ventures, Jump Capital, and Wintermute Ventures among the other named investors. The company pitches itself as an “always-on” bank running continuous, blockchain-based settlement instead of the batch-processing rails – ACH, wire transfers – that traditional banks still depend on.

Its business plan centers on tokenized deposits, treasury management, foreign correspondent banking, and a banking-as-a-service platform aimed at institutional clients. Diwakar Choubey, who co-founded the company with Richard Correia after running MoneyLion, framed the harder full-service charter path as a deliberate choice rather than the easier route most crypto firms have taken.

“We chose the national bank path deliberately,” he said in a statement announcing the approval, according to the company’s release.

OpenReserve Enters a Growing Crypto-Bank Charter Push

That path separates OpenReserve from most of its crypto-charter peers. Coinbase, Circle, Ripple, Paxos, and BitGo all pursued national trust charters instead, a route that permits custody and fiduciary work but blocks deposit-taking and lending outright.

A full national bank charter would let OpenReserve do both – deposits and lending – once it clears final approval and satisfies the applicable requirements. That’s a materially different regulatory ask than the trust-bank model, and it explains why the process took nearly five months of review rather than the faster clocks trust applicants have seen.

OpenReserve wasn’t the only recipient of a national bank charter 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 cast as a broader push to bring firms working on novel technology into the federally supervised banking system.

That pace hasn’t gone unchallenged. Senator 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 approved a national trust charter for the Trump-linked World Liberty stablecoin venture that August anyway.

The Stablecoin Plan Still Requires Its Own Regulatory Path

OpenReserve also intends to spin up a separate, wholly owned subsidiary to issue and redeem U.S. dollar-denominated, reserve-backed stablecoins. That subsidiary hasn’t filed its own OCC application yet, which means the bank charter approved this week does not itself authorize stablecoin issuance.

Any stablecoin activity the subsidiary eventually pursues will have to comply with the GENIUS Act, the federal law governing stablecoin operations. For investors tracking the sector, the distinction matters: a national bank charter and a stablecoin issuer license are two separate regulatory processes, and OpenReserve currently holds neither in final form – it has preliminary approval on the bank side and no filing yet on the stablecoin side.

That’s a slower runway than some of the market commentary around the announcement might suggest, and it’s worth watching whether the subsidiary application actually gets filed before assuming stablecoin issuance is close.

Capital, Final Approval and the Stablecoin Filing Come Next

Three concrete milestones now separate OpenReserve from an operating bank. It needs to raise the $210 million in paid-in capital by September 2027, open its doors by March 2028, and hold that 12% Tier 1 leverage ratio through its first three years once it does open.

Layered on top of that, the OCC’s pre-opening requirements and final clearance still have to be satisfied – preliminary approval is a gate passed, not the finish line. And the planned stablecoin subsidiary still needs to file its own application before that piece of the business plan can move forward at all.

For a company barely a year removed from its seed round, that’s a demanding checklist, and each of those dates is a real catalyst worth tracking rather than a formality.

Follow CoinNews for More Market Updates

Follow CoinNews on X and Telegram for ongoing coverage of crypto banking charters and regulatory milestones.