A pivotal move by the U.S. Office of the Comptroller of the Currency (OCC) is set to redefine how national banks interact with public blockchain networks. Interpretive Letter 1186, issued on November 18, 2025, grants significant new permissions, clearing a pathway for regulated financial institutions to engage more deeply and directly with the decentralized infrastructure that underpins the crypto ecosystem. This guidance, though seemingly technical, carries profound implications for the future of institutional participation in digital assets.
New Pathways for Bank Engagement
The OCC's letter empowers national banks to hold native crypto assets and pay blockchain network fees directly, a critical development that removes a long-standing barrier to direct blockchain interaction. Previously, regulated banks faced significant hurdles in acquiring and storing the foundational digital assets, like those for Ethereum or Solana, necessary to operate on these networks. Now, banks can acquire and store these native tokens specifically for operational needs, such as facilitating transactions and testing blockchain platforms, both internal and third-party. This marks a clear authorization for banks to integrate blockchain technology into their operational frameworks, treating these digital assets as essential components for network functionality rather than speculative investments.
Bridging Traditional Finance and Decentralized Networks
Beyond simply holding assets, the new guidance implicitly opens the door for national banks to participate in proof-of-stake validation. The OCC letter authorizes activities that closely align with validator requirements, including holding native tokens, paying network fees, processing transactions, and crucially, receiving network rewards. While "staking" isn't explicitly named, the authorization to receive rewards for operating nodes strongly suggests a path toward full validator participation. The OCC frames these activities not as novel ventures, but as extensions of existing banking functions, drawing parallels to how banks have historically held foreign currency reserves or shares in payment networks to facilitate operations and meet customer demand. This framing underscores a regulatory perspective that views blockchain networks as modern equivalents of traditional payment infrastructures.
A Quiet Shift with Broad Implications
This interpretive letter, presented as a clarification, represents a quiet yet significant shift in the regulatory landscape, potentially reshaping U.S. banks' interaction with blockchain technology. The ability for banks to directly hold native tokens, pay gas fees, and run nodes enables them to participate directly in blockchain consensus mechanisms. Such involvement from regulated institutions could significantly influence crucial aspects of the crypto ecosystem, including network decentralization, staking yields, and the broader institutional access to on-chain infrastructure. It also signals a maturing regulatory environment where public blockchains are increasingly recognized and integrated into traditional financial systems, fostering closer interaction between these previously distinct worlds.
