Two Digital Banks Receive Preliminary Approval, Operations Yet to Begin

The Office of the Comptroller of the Currency (OCC) has granted preliminary conditional approval for the establishment of national banks by Revolut and OpenReserve. Both companies proposed integrating digital asset services such as cryptocurrency custody, access to stablecoins, and tokenized deposits into their banking operations.

The OCC announced on September 2 that it had granted preliminary conditional approval for the establishment of Revolut Bank US in its corporate decision number 1390. On the same day, it also granted preliminary conditional approval for OpenReserve Bank's national bank establishment in corporate decision number 1389. This approval is not a final operating license; both banks must meet requirements before opening and undergo final approval from the OCC, Federal Deposit Insurance Corporation (FDIC) insurance, and Federal Reserve procedures.

Revolut Bank US is applying to be a full-service digital bank headquartered in Stamford, Connecticut. The OCC documents outline plans to offer deposit, loan, payment services, and digital asset services. Cryptocurrency custody will be provided through a non-custodial trust structure via a subsidiary regulated by the UK's Financial Conduct Authority (FCA).

Revolut also proposed a method for customers to make international transfers using digital assets, including stablecoins. However, Revolut Bank US will not directly issue its own branded stablecoins or manage reserve assets. The OCC documents limit the bank's role to marketing, customer access, and custody services for third-party issued stablecoins.

In a statement on the 3rd, Nik Storonsky, founder and CEO of Revolut, stated that "the conditional OCC approval is an important first step towards establishing Revolut Bank US." The company explained that once all approvals are obtained, it can directly offer loans, credit cards, FDIC-insured deposits, and access to stablecoins and cryptocurrencies to U.S. customers.

OpenReserve Bank is applying to be a full-service national bank headquartered in Salt Lake City, Utah. The OCC documents list deposit and loan services, tokenization features for all deposit products, payment and financial management, digital asset services, foreign exchange banking, and banking-as-a-service platforms as part of its business scope.

OpenReserve's structure is more aligned with stablecoin issuance than Revolut's. The OCC documents indicate that OpenReserve plans to establish a 100% subsidiary for a stablecoin company to handle the issuance, custody, conversion, and payment of dollar-backed stablecoins. The application for this subsidiary has not yet been submitted.

OpenReserve must align its business structure, including stablecoin issuance, with the U.S. Stablecoin Act (GENIUS Act) and future regulations. This means that the issuance of stablecoins, management of reserve assets, and redemption structures may be subject to separate regulatory frameworks, independent of the bank's license itself.

Capital requirements also differ. Revolut Bank US must maintain a minimum initial paid-in capital of $95 million (approximately 128 billion KRW), excluding pre-opening costs. OpenReserve Bank's initial paid-in capital requirement is at least $210 million (approximately 283 billion KRW).

OpenReserve must maintain a core capital leverage ratio of over 12.0% during its first three years of operation. The same requirement for Revolut Bank US is over 10.0%. The core capital leverage ratio is a soundness indicator that compares a bank's core capital to its total exposure, serving as a benchmark for assessing the initial bank's loss absorption capacity.

The key aspect of this decision lies in the 'conditions' rather than the 'approval.' Preliminary conditional approval means that the bank establishment process can continue, but it does not imply that deposit acceptance or cryptocurrency services can commence immediately. Previously, it was reported that Revolut and OpenReserve had received preliminary conditional approval from the OCC.

The backdrop for digital asset companies pursuing U.S. bank licenses is a trend to bundle custody, payment, deposit, and stablecoin services under the same regulatory framework. Until now, cryptocurrency companies often used separate banks, trust companies, and custodians. Once national bank licenses are finalized, the scope of operations and supervisory systems may become clearer.

However, obtaining a bank license does not automatically allow all digital asset services. The OCC stated in both decisions that it can modify, suspend, or revoke preliminary approvals until final approval is granted. Revolut and OpenReserve can only begin banking operations after passing pre-opening reviews and obtaining separate regulatory approvals.

In the Korean market, this decision may serve as a reference case at the intersection of stablecoins and banking. Issues such as deposit insurance, reserve asset management, custody responsibilities, and the legal nature of tokenized deposits continue to be discussed domestically. The actual launch of operations by both companies will be possible only after the OCC's final approval and the completion of FDIC deposit insurance and Federal Reserve-related procedures.

This content is provided for general informational purposes only and doesn't constitute financial, investment, legal, or tax advice. Any events, rewards, online promotions, or related information mentioned herein should not be considered a recommendation, solicitation, or invitation to purchase, sell, trade, or otherwise deal in any crypto assets. Crypto assets are highly volatile and may result in loss. The availability of WEEX services, products, and related events may vary by region. You are responsible for ensuring that your participation is in accordance with applicable local laws and regulations.