Revolut and OpenReserve Get OCC Nod: Milestone or Regulatory Gamble?
Preliminary OCC approval puts Revolut and OpenReserve on the path to US bank charters — with both promise and peril.
Revolut and OpenReserve have received preliminary clearance from the U.S. Office of the Comptroller of the Currency (OCC) to charter national banks, with plans to offer crypto services. The approvals are not final banking licenses — they are early, conditional steps — but they put crypto-native firms on a federal banking track that has generated both optimism and pushback.
What the preliminary approval actually is
An OCC charter application goes through multiple gates. A "preliminary" or "initial" approval typically signals that the OCC has reviewed the proposed business plan and found it legally permissible, but the applicant must still satisfy conditions — capital requirements, governance standards, supervisory expectations — before the charter is granted. For Revolut and OpenReserve, that means the destination is a national bank charter whose activities could include custodying or transacting in crypto assets, under federal rather than patchwork state-level oversight.
What supporters see: a bridge into the system
- Federal supervision could give crypto services a clearer regulatory status than operating as unlicensed money transmitters or relying on state licenses.
- A national charter may allow firms to operate across all US states without separate approvals, potentially expanding consumer access to crypto products.
- Banking regulators bring established frameworks for capital, risk management, and consumer protection, which advocates say could make crypto services safer for retail customers.
- Companies like Revolut already operate as regulated financial firms in other jurisdictions; a US charter would align crypto offerings with tested banking standards.
What critics and regulators worry about
- Crypto businesses have a track record of volatility and custody failures; folding them into the bank safety net may expose depositors and the deposit insurance fund to unproven risks.
- Critics argue that preliminary approval may be granted before robust rules exist for supervising crypto within a national bank.
- A bank charter imposes strict capital and liquidity requirements that can be at odds with crypto market conditions, potentially pushing risk into less transparent corners.
- There is also concern about regulatory arbitrage — firms seeking a charter for legitimacy while still engaging in under-regulated token activities.
- Even OCC leadership has historically been split on whether crypto at federally chartered banks should be celebrated or slowed, so the process remains contested.
The balanced takeaway
This preliminary approval does not mean Revolut and OpenReserve are banks today, nor does it mean they will never be. It means the OCC is willing to explore whether crypto services can live inside a federally chartered bank. Whether that leads to safer integration or to a new set of contagion risks depends entirely on the conditions attached — and on how rigorously those conditions are enforced.
What to actually watch next
The meaningful signals are not in headlines but in details: the specific conditions the OCC attaches as charters move from preliminary to final, how the institutions design their compliance and custody systems, and whether any enforcement actions follow. Also watch how state-level crypto frameworks respond to a potential federal alternative, and whether other crypto firms file similar applications. Those developments will determine what these charters mean in practice.
What is an OCC preliminary approval?
It is an early-stage, conditional clearance that a company's bank charter application is acceptable in principle. The OCC can still impose requirements and the applicant must pass further review before a full national bank charter is granted.
Are Revolut and OpenReserve banks now?
No. A preliminary clearance is not a final charter. They have been cleared to move forward in the application process, not authorized to open bank operations.
Does the OCC approval let them offer crypto to everyone?
Not yet. It signals the OCC views their proposed business model, including crypto services, as permissible under federal banking law. But actual offerings require a final charter and compliance with any conditions imposed.
Why is this controversial?
Supporters see crypto firms gaining legitimate federal oversight and consumer protections. Critics fear banking regulators are approving untested crypto business models too early, exposing the banking system and customers to new risks without clear supervisory rules.
What does this mean for other crypto companies?
It could establish a pathway for crypto firms to obtain national bank charters if they meet OCC conditions. Other firms may follow suit, but each application is reviewed individually and outcomes can vary.