Revolut and OpenReserve Win Preliminary Approval for US National Bank Charters

The US Office of the Comptroller of the Currency has granted preliminary conditional approval for Revolut and OpenReserve to operate full-service national banks, a milestone that puts two digital-asset-focused lenders one step closer to offering federally chartered banking in the United States. Reuters reported on September 3 that Revolut, the British fintech with roughly 80 million customers worldwide, plans to inject about $95 million into a proposed bank in Stamford, Connecticut, while crypto-focused OpenReserve must raise at least $210 million in initial paid-in capital for its Salt Lake City charter. CoinDesk reported on September 3 that the OCC's decision letters were dated September 2 and 3, and in-window coverage by Cointelegraph on September 4 and 5 confirmed the scope of both approvals.

The approvals are preliminary, not final. Both companies still face a list of preopening conditions, and Revolut in particular must also clear the Federal Deposit Insurance Corporation and the Federal Reserve before it can open, since a national bank charter alone does not confer deposit insurance. But the OCC sign-off is the hardest regulatory hurdle for most applicants, and it signals that the agency, under Comptroller Jonathan Gould, is comfortable chartering banks whose business models are built around digital assets rather than merely tolerating them on the side.

The distinction between these charters and the ones crypto companies have historically obtained matters. Earlier crypto entrants, such as Anchorage and BitGo, received trust bank charters that prohibit deposit-taking and lending. The Revolut and OpenReserve approvals are for full-service national bank charters, which allow deposits, lending, payments and stablecoin-related services, a far broader license that puts the two companies on a path to compete with traditional banks rather than simply custodying assets for them.

Key Facts

The OCC's decisions were formalized in corporate decision letters numbered 1389 and 1390, dated September 2 and 3. Reuters reported on September 3 that OpenReserve's charter requires the company to raise at least $210 million in initial paid-in capital, net of organizational and preopening expenses, and to maintain a Tier 1 leverage ratio of 12 percent for its first three years of operation, a figure far above the 5 percent standard applied to conventional banks.

Revolut's path includes a significant capital commitment of its own. CoinDesk reported on September 3 that Revolut plans a roughly $95 million capital injection into its proposed Stamford, Connecticut bank, and the company still needs approval from the FDIC and the Federal Reserve before it can begin operations. Revolut has said it targets a full US banking launch in 2027, and its planned products include checking accounts, installment loans, credit cards and foreign exchange, alongside a stablecoin it intends to offer to its global customer base.

OpenReserve, founded by Diwakar "Dee" Choubey, the founder of MoneyLion, and Richard Correia, is building a bank around on-chain settlement. Its application was constructed around the GENIUS Act stablecoin framework, and its investors include a16z crypto, Coinbase Ventures, Jump Capital, Acrew and Wintermute Ventures. CoinTelegraph reported on September 4 that OpenReserve previously raised a $25 million seed round led by a16z crypto, and the company says its platform will offer tokenized deposits, digital asset custody and a US dollar-backed stablecoin through a subsidiary whose application has not yet been filed.

The broader context is a surge of digital-asset banking applications. Comptroller Jonathan Gould has said that 23 of the 40 pending de novo bank charter applications before the OCC involve digital assets, a figure that underlines how central crypto has become to the future of the chartering pipeline. The agency has already granted conditional approvals to Coinbase, Paxos, BitGo, Ripple and Circle, and the Revolut and OpenReserve decisions extend that pattern from crypto-native firms to a mainstream fintech with tens of millions of users.

Analysis

What this really means is that the OCC has decided that the way to regulate digital-asset banking is to charter it, not to force it into the shadows. The agency's willingness to approve full-service charters for Revolut and OpenReserve, rather than confining them to narrow trust licenses, is a deliberate policy choice that treats stablecoin issuance and tokenized deposits as legitimate banking activities deserving of federal supervision. The 12 percent leverage requirement on OpenReserve and the $95 million capital injection demanded of Revolut show that the OCC is not being lenient; it is imposing bank-style capital discipline on business models that, until recently, operated outside the banking system entirely.

The bigger picture here is that the approvals collapse the distinction between fintech and banking that has defined the last decade of financial regulation. Revolut has spent years serving customers through partner banks, and its 80 million global customers have been, in a legal sense, someone else's customers. A national bank charter changes that relationship permanently: Revolut becomes the bank, with its own deposits, its own lending and its own regulatory obligations, and the $95 million capital injection is the price of admission to a club it has been circling since its founding.

There are real risks hidden in the milestone. Full-service charters bring full-service supervision, including examination costs, capital requirements and the compliance burden of the Bank Secrecy Act, and neither company has ever operated under that regime at scale. The 12 percent leverage ratio on OpenReserve is a reminder that the OCC views on-chain banking as riskier than the average community bank, and a market downturn in crypto assets would test whether either institution's capital buffer is adequate. The approvals also put the two companies in direct competition with the very banks they once served as technology partners, which will make their existing partnerships awkward at best.

Why It Matters

For consumers, the approvals mean that the stablecoin and digital-asset services that millions of people already use could soon come with federal deposit insurance and bank-level protections, at least once Revolut clears the FDIC and Federal Reserve hurdles. A federally chartered Revolut would be able to offer checking accounts, credit cards and loans alongside crypto custody and stablecoin transfers, a combination that no single US institution offers today. OpenReserve's on-chain bank, if it opens, would give depositors a regulated venue for tokenized deposits that settles around the clock rather than during banking hours.

For the banking industry, the decisions are a competitive warning. Traditional banks have watched fintechs take their customers' front-end experience while relying on their back-end charters, and the OCC's approvals allow the most ambitious fintechs to cut out the middleman entirely. The 23 of 40 pending charter applications that involve digital assets suggest the wave is only beginning, and community banks that have treated fintech partnerships as a growth strategy may find their partners becoming competitors.

The design of the approvals also hints at how the OCC wants this new generation of banks to behave. The 12 percent leverage requirement imposed on OpenReserve is roughly two and a half times the 5 percent standard applied to conventional banks, and the insistence on initial paid-in capital of at least $210 million, net of organizational expenses, is a way of ensuring that the applicant has real skin in the game before it takes a single deposit. Regulators are effectively telling digital-asset banks that they are welcome in the system, but they will be held to a stricter safety-and-soundness bar than their traditional peers until they prove their business models can survive stress. That asymmetry is likely to persist for years, and it is the price of admission that every future digital-asset charter applicant should now expect to pay.

Next Up

The next regulatory gate is Revolut's path through the FDIC and the Federal Reserve, which will determine whether it can actually open in 2027 as planned. Watch for the agency to scrutinize Revolut's global business model, including its history with regulators in other markets, and for OpenReserve to begin the process of raising its $210 million in paid-in capital, a test of whether its investor base can fund a bank as well as a startup. The OCC's decision on OpenReserve's stablecoin subsidiary application, once filed, will be the next signal of how far the agency is willing to go in chartering the on-chain banking model.