In May, few truly grasped the significance of the Office of the Comptroller of the Currency (OCC) Interpretation Letter 1184, so I reiterate it here:
The OCC, responsible for regulating national banks (specifically national banks and Federal Savings Associations), is now authorized to buy and sell Bitcoin, Solana, Ethereum, and XRP (any commodity held by a regulated ETF) on behalf of clients. This stems from a key guidance issued by the OCC in 2025: In May 2025, OCC Interpretation Letter 1184 explicitly stated that national banks can buy and sell custodied crypto assets at the instruction of clients. Banks can also outsource related services (such as trade execution) to third parties, provided that risk management is appropriate. This effectively allows banks to execute trades on behalf of clients.
In December 2025, the OCC further clarified in Interpretation Letter 1188 that banks are permitted to conduct “risk-free principal” trading of crypto assets. In these models, banks act as intermediaries: they purchase assets (such as Bitcoin) from one counterparty and simultaneously sell them to another, without holding large inventories or incurring significant balance sheet risk. This is similar to how banks currently provide brokerage services for other assets such as securities, and removes a major regulatory hurdle previously faced.
This builds on the Office of the Comptroller of the Currency's (OCC) previous approvals of cryptocurrency custody services (dated as early as 2020 and reaffirmed and expanded in 2025), stablecoin activities, and related businesses. Other regulators, such as the Federal Deposit Insurance Corporation (FDIC), have also withdrawn restrictive guidance and made it clear that banks do not need prior approval to engage in permitted cryptocurrency activities as long as risks (cybersecurity, anti-money laundering, etc.) are under control. Some banks have already begun launching related services: for example, PNC Bank offers Bitcoin spot trading services to select clients through partnerships with companies like Coinbase; Bank of America is resuming/expanding its Bitcoin custody services for institutional clients.
However, banks will not engage in indiscriminate speculation, nor will they hold large cryptocurrency positions on their balance sheets for profit (in many cases, this practice remains restricted).
The focus is on client-oriented custody services and brokerage-style trade execution.
