On March 7, 2025, the OCC issued Interpretive Letter 1183, which reaffirms that national banks may engage in certain crypto-asset activities discussed in prior interpretive letters, and—expressly rescinding Interpretive Letter 1179—that they may do so without first obtaining supervisory non-objection from the OCC. In particular, national banks may (i) provide crypto-asset custody services, (ii) hold deposits backing stablecoins as reserves and (iii) engage in certain other stablecoin and payment activities.
To date, neither the FDIC nor the Federal Reserve Board has modified or withdrawn their existing crypto-asset activity guidance, which includes, among other things, a prior notification requirement for banks subject to their respective jurisdictions to engage in crypto-asset activities similar to the requirement just rescinded by the OCC. Unless and until the FDIC and Federal Reserve Board modify their current supervisory approach to crypto-related activities, different banks may be subject to differing limitations on their ability to engage in crypto-asset-related activities.