OCC Guidance: Banks May Hold Crypto for Blockchain Network Fees
The U.S. Office of the Comptroller of the Currency (OCC) has issued Interpretive Letter No. 1186, giving national banks the green light to hold crypto on their balance sheets for the purpose of paying blockchain network fees. Blockchain networks require native tokens to process transactions; these fees, often called "gas fees," are unavoidable. The OCC said banks can hold the tokens they reasonably anticipate needing, including paying fees as part of crypto custody services or facilitating client transactions. The goal is to reduce reliance on third-party providers and lower operational risks. "Paying network fees is a necessary part of doing business on blockchain networks," the OCC stated. "Holding crypto for this purpose is permissible when it supports otherwise lawful banking activities."
'Incidental' Banking Uses and Regulatory Implications
The guidance emphasizes that these activities are "incidental to the business of banking." That phrase carries legal weight: it means banks can do it legally as long as the activity helps them serve customers or operate efficiently. The OCC drew parallels to historical banking practices, such as holding foreign currency, banknotes, or shares in payment systems to facilitate transactions. In other words, banks have always needed to hold certain assets to do business; crypto is just the latest form. Banks are expected to manage risks carefully, tracking operational, market, liquidity, cybersecurity, and legal risks. The amount of crypto held should remain minimal relative to the bank's capital. The letter comes under the leadership of Comptroller Jonathan Gould, a Trump appointee confirmed in July 2025. Under his tenure, the OCC has become more crypto-friendly. Earlier guidance allowed banks to act as nodes on blockchain networks, offer crypto custody services, and work with stablecoins.
Impact on Banking and Crypto Adoption
Meanwhile, broader rules for stablecoin issuers under the GENIUS Act are still being drafted. But the OCC's move signals that U.S. regulators are willing to let banks participate in crypto safely and efficiently. As more banks explore digital assets, this guidance could accelerate adoption, bridging traditional finance and blockchain and giving banks a clearer path to integrate crypto into everyday operations. Earlier this year, the OCC issued guidance (Interpretive Letter 1184) allowing national banks and federal savings associations to offer cryptocurrency custody and trading services. Essentially, banks can buy and sell digital assets on behalf of customers, outsource crypto activities to third parties, and provide related services like recordkeeping, tax reporting, and compliance.