Overview
- Interpretive Letter 1186 authorizes national banks to keep small amounts of native crypto on balance sheet to pay blockchain network fees for otherwise permissible activities.
- Banks may pay fees on behalf of customers and in custody operations, and they can hold tokens to test internal or third‑party crypto platforms before production use.
- The OCC requires that holdings remain minimal relative to capital and be managed under controls for market, liquidity, operational, cybersecurity and legal risks.
- The guidance reduces reliance on third‑party intermediaries for fee payments and ties crypto usage to long‑standing “incidental to banking” precedents.
- Observers say the clarification could pave a path to running nodes or participating in proof‑of‑stake validation, a developing possibility as interagency stablecoin rules are still being drafted under the GENIUS Act.