Revolut and OpenReserve cleared a critical regulatory hurdle Friday as the Office of the Comptroller of the Currency granted preliminary approval for both firms to organize national banking associations with cryptocurrency and stablecoin services baked into their business plans.
The conditional nod represents the furthest any major fintech or crypto-native company has advanced in the US national bank charter process.
Market data shows revolut, the UK-based financial super-app with 45 million global users, and OpenReserve, a stablecoin infrastructure startup backed by Paradigm and Coinbase Ventures, now enter the formal organization phase, a period that typically spans 12 to 18 months before a final charter is issued.
What the preliminary approval actually means
The OCC's preliminary conditional approval authorizes each firm to begin the legal and operational work of forming a national bank: hiring directors, adopting bylaws, establishing capital structures, and filing the formal charter application. It does not grant permission to operate.
Both companies must still satisfy all standard national bank requirements, minimum capital, anti-money-laundering programs, consumer compliance frameworks, and Federal Reserve membership, before the charter becomes effective. Revolut's application outlines plans for crypto custody, spot trading, and stablecoin-related services for its US customer base.
OpenReserve's filing centers on issuing a USD-denominated stablecoin and providing settlement rails for institutional counterparties. Neither firm has disclosed target launch dates.
How the two proposals differ
| Entity | Core Focus | Stablecoin Plan | Backing |
|---|---|---|---|
| Revolut | Consumer fintech + crypto custody/trading | Integration with existing stablecoins | Self-funded, $33B valuation |
| OpenReserve | Institutional settlement infrastructure | Native USD stablecoin issuance | Paradigm, Coinbase Ventures |
OpenReserve built its entire model around the national bank charter as the regulatory foundation for a new stablecoin issuer, a structure the OCC has previously endorsed in interpretive letters but never yet chartered.
Why the timing matters
The dual approvals arrive as the OCC, Federal Reserve, and FDIC continue a joint policy sprint on crypto-asset activities for banking organizations. In January 2025, the agencies issued a joint statement affirming that banking organizations can engage in crypto-asset activities provided they manage risks effectively.
The Revolut and OpenReserve preliminary approvals are the first concrete charter actions since that guidance. Market observers note the OCC moved on both applications simultaneously, a departure from the sequential reviews typical of novel charter types.
The parallel track suggests the agency is building a cohort of crypto-integrated banks rather than treating each as a one-off experiment.
Both firms now enter the organization period. Revolut must demonstrate how its UK-based group structure maps to US bank holding company requirements. OpenReserve must finalize its stablecoin reserve composition, audit framework, and redemption mechanics to OCC satisfaction.
The Federal Reserve will separately review each firm's master account application for payment-system access. A final charter decision for either firm is unlikely before mid-2027 based on historical timelines for de novo national banks with novel business lines.
The supply signal
For stablecoin markets, the OpenReserve charter track is the more consequential signal. A national bank charter would allow OpenReserve to issue a stablecoin with direct Federal Reserve master account access, a structural advantage over current issuers that rely on correspondent banking relationships.
Revolut's path matters more for retail distribution: a chartered bank could offer stablecoin yields, payments, and custody under a single regulated roof, potentially accelerating mainstream adoption. The OCC's willingness to advance both models simultaneously suggests the regulator sees room for multiple crypto-integrated banking architectures rather than a single approved template.
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