Policy
OpenReserve Needs $210 Million by September 2027 to Open Its Approved Bank
The OCC gave a blockchain settlement startup preliminary approval to charter a full-service national bank — then attached a capital bar eight times its seed round and a leverage ratio twice what ordinary national banks carry. The conditions are the decision.
The headline version of this week's news is that a blockchain company got a national bank charter. That version is wrong in two directions at once, and the ways it is wrong are more interesting than the version itself.
What the Office of the Comptroller of the Currency actually granted OpenReserve Holdings, first reported by CoinDesk on September 3, is preliminary conditional approval. That is the beginning of a process, not the end of one. Nobody can deposit anything at OpenReserve today, and on the timeline its own filings describe, nobody will be able to for a year and a half.
But the other direction matters more. This is not a trust charter or a limited-purpose vehicle of the kind the OCC has handed to crypto custodians. It is preliminary approval for a full-service insured national bank — deposits, lending, payments, treasury services — built, in the company's framing, on a programmable core ledger with native on-chain settlement. That is a materially bigger door than the ones opened so far.
Read the conditions, not the approval
Approvals like this are shaped almost entirely by what is attached to them, and what the OCC attached here is unusually heavy.
The Block reported that OpenReserve must raise at least $210 million in initial paid-in capital and hold a Tier 1 leverage ratio of at least 12% through its first three years of operation. Forkast puts the deadline for closing that raise at September 2027, with a target opening in March 2028.
Take the leverage figure seriously, because it is the one a general reader will skate past. A Tier 1 leverage ratio is capital measured against total assets, without the risk-weighting that lets banks hold less against assets a regulator considers safe. Forkast notes the ordinary supervisory expectation sits around 5%. Twelve percent is more than double that, and it is not a one-off gate — it is a standing constraint for three years, which means it governs how large OpenReserve's balance sheet is permitted to grow relative to whatever capital it holds. A bank told to run at 12% leverage is a bank told, in the only language supervision really has, that its regulator does not yet know how its assets will behave.
The $210 million is the same message in a blunter form. OpenReserve has raised a $25 million seed round, led by a16z crypto with participation from Jump Capital, Acrew, Coinbase Ventures, Wintermute Ventures, Clocktower, Quona, AAF Management and Zero Knowledge Ventures. The capital condition is roughly eight times that. Whatever else the OCC did this week, it did not make OpenReserve a bank. It told OpenReserve what a bank would cost.
What was granted, and what is still required
| Item | Status |
|---|---|
| Preliminary conditional approval, national bank charter | Granted |
| Initial paid-in capital | $210M required, due Sep 2027 |
| Tier 1 leverage ratio, first three years | ≥12% (ordinary expectation ~5%) |
| FDIC deposit insurance | Still to obtain |
| Federal Reserve Bank stock | Still to apply for |
| ReserveUSD stablecoin subsidiary | Separate approval, not yet filed |
| Final approval and opening | Targeted Mar 2028 |
What the bank is actually for
Strip away the ledger vocabulary and OpenReserve's pitch is narrow and specific: settlement that works when the existing plumbing is closed. The company describes offering "24/7 atomic on-chain settlement during the hours when traditional banking infrastructure goes dark" — nights, weekends, and the long gaps around holidays when a wire simply waits.
That is a real problem and an unglamorous one. It is also the problem stablecoins solved commercially before anyone solved it institutionally, which is why the subsidiary matters. OpenReserve plans a wholly owned entity, ReserveUSD, for the issuance, custody, conversion and payment of dollar-denominated reserve-backed stablecoins. The Block notes that subsidiary has not filed its own application yet. So the most consequential piece of the business — a nationally chartered bank issuing its own stablecoin — is the piece with no approval attached to it at all.
The founders are not crypto natives, and that is probably the point. Dee Choubey previously founded MoneyLion; Rick Correia came through Merrill Lynch and Citadel. This is a fintech-and-markets team applying for a bank charter, not a protocol team, and the application reads like one.
The queue behind it
One approval is an anecdote. The pipeline is the trend, and the two outlets frame it differently enough that both numbers are worth carrying.
The Block reports that under Comptroller Jonathan Gould the OCC has approved 21 of 40 de novo charter applications since 2025, with conditional approvals going to Coinbase, Paxos, BitGo, Ripple and Circle. Forkast, describing the current pipeline rather than the approval record, reports that of 40 pending applications, 23 involve digital assets. Those are not the same statistic and we are not going to blend them. Read together they describe the same weather: a chartering process that has become, in the space of about eighteen months, majority crypto by volume.
That is the genuinely new thing here. The argument of the last decade was whether crypto firms should be allowed inside the perimeter of federal banking supervision. That argument appears to be over. What replaced it is a quieter and more technical negotiation about price — how much capital, at what ratio, on what timeline, with which activities pushed into separately supervised subsidiaries. OpenReserve is the current answer to that question, and the answer is $210 million, 12%, and eighteen months of proving it.
Update, September 9: the historical baseline
Three days after this story published, Block filed its own application with the OCC to establish Builders Bank & Trust, N.A., an uninsured national trust bank that would custody bitcoin and stablecoins while taking no deposits and making no loans. The filing supplies the piece of context this story was missing: not how many applications the agency is holding, but how unusual that number is.
Per PYMNTS, the OCC received 48 de novo charter applications across the fourteen years from 2011 to 2024. It has received roughly 40 in the eighteen months since the start of 2025. Annualize both and the rate has gone from about 3.4 applications a year to about 27 — an eightfold increase, by this desk's arithmetic on those published totals.
That reframes the conditions attached to OpenReserve's approval. A $210 million capital requirement and a 12 percent leverage ratio read one way as a judgement about one applicant's business model, and another way as a tool an agency reaches for when its inbound volume has multiplied and its examination capacity has not. The OCC does not staff up eightfold because filings did. Conditions that are expensive to satisfy do work that supervision would otherwise have to do — they filter applicants by their ability to fund the commitment, before anyone opens.
Nothing in the public record says the OCC set OpenReserve's numbers for that reason, and this desk is not asserting it did. But the pattern is now visible enough to watch: if the conditions attached to the next several approvals cluster around capital bars and multi-year deadlines rather than activity restrictions, the agency will have found a way to say yes at volume while keeping the number of institutions it actually has to examine roughly flat.
The Take
The reflex reading — regulator waves crypto bank through — gets the direction right and the substance backwards. An agency that wanted to wave this through would not demand eight times the company's total funding and hold it at double-normal leverage for three years. Those conditions are what caution looks like when it has decided to say yes: the OCC is permitting the experiment and pre-funding its failure, so that if a programmable-ledger bank turns out to behave unlike the models predict, the losses land on shareholders rather than the insurance fund. That is a defensible way to run a novel-charter process, and it is worth noticing that the binding constraint on crypto banking in the United States is now arithmetic rather than ideology. The honest caveat is that none of this has been tested. Preliminary approvals expire, capital raises fail, and the most important part of OpenReserve's business — its stablecoin arm — has not been examined by anyone yet. March 2028 is a long way off, and the number of chartered crypto banks actually taking deposits today remains zero.