A Bank That Never Closes: OpenReserve Wins OCC Preliminary Charter Approval
OpenReserve Holdings received preliminary conditional approval from the U.S. Office of the Comptroller of the Currency on September 2 to charter a full-service insured national bank in Salt Lake City, Utah. The approval, granted under OCC Corporate Decision CD1390, positions the a16z-backed startup to offer treasury management, stablecoin issuance, and tokenized deposits on a 24/7 basis if it clears several significant remaining conditions.
The startup filed its application on April 13, 2026, and the OCC ruled in approximately 142 days, just under five months. The agency has processed many de novo applications in four to five months as part of its recent posture of accelerating reviews. The OCC has received 40 de novo applications over the past 18 months, including limited-purpose trust bank applications, and has separately issued guidance confirming that national banks may provide digital asset custody and settlement services, and may act as agents to execute and settle digital asset trades, all in a "safe and sound manner." The agency has publicly described itself as "open for business" for crypto applicants.
OpenReserve was founded by Dee Choubey, who previously co-founded MoneyLion, a personal finance and lending platform. The company has raised $25 million in seed funding, led by Andreessen Horowitz (a16z), with additional participation from Jump Capital, Coinbase Ventures, and Wintermute Ventures. Andreessen Horowitz closed its fifth crypto-focused fund at $2.2 billion in May 2026, bringing the firm's total crypto allocations to $9.8 billion across five vehicles.
"Preliminary conditional approval to charter a de novo national bank is a privilege our team does not take lightly," Choubey said in a statement. The bank's architecture is designed around continuous settlement, unlike traditional banks constrained by Federal Reserve operating windows. Guy Wuollet, a general partner at a16z, described the thesis plainly: "We need a bank that's always on, always open, always available. A bank that never closes."
The approval is conditional and OpenReserve is not yet operational. The OCC requires the company to raise $210 million in paid-in capital before final approval, maintain a minimum Tier-1 leverage ratio of 12 percent for its first three years, and clear a pre-opening examination. Capital must be raised within 12 months; banking operations must commence within 18 months. OpenReserve must also obtain FDIC deposit insurance separately. Its planned stablecoin subsidiary requires a distinct filing under the GENIUS Act (the Guiding and Establishing National Innovation for U.S. Stablecoins Act, signed into law in July 2025), which mandates 1:1 reserves backed by USD cash, short-term Treasuries, or other approved low-risk assets, and requires regular audits. The OCC has specified that crypto transaction fees must be converted to fiat within one business day, with limited exceptions.
The charter type matters more than the approval itself. Most crypto firms pursuing OCC recognition, including Paxos, Crypto.com, and Ripple, have applied for limited-purpose national trust bank charters. Those structures permit custody and settlement but prohibit insured deposit-taking or lending. OpenReserve is seeking a full-service insured national bank charter, placing it in a narrower category alongside Erebor Bank, N.A., which is backed by Palmer Luckey, Joe Lonsdale, and Founders Fund (associated with Peter Thiel), and which recently became the first full-service national bank to receive final OCC approval and begin operations after a multi-year gap in de novo national bank approvals. Circle received final OCC approval in July 2026 for a limited-purpose national trust bank charter, operating as First National Digital Currency Bank, N.A. That structure is a distinct tier that permits custody and settlement but does not allow insured deposit-taking or lending.
For users outside the United States, particularly in South Asia and Africa, the structural implications are significant even if OpenReserve has not announced specific products targeting those regions. India is the world's largest remittance recipient and the U.S.-India corridor is among the highest-volume globally. Traditional cross-border wire transfers on that corridor carry fees of 2 to 7 percent and settle in three to five days. Stablecoin rails now settle near-instantly for less than one dollar per transaction, and 67 percent of Indian B2B executives using stablecoins with U.S. counterparts report faster cash flow, according to Stablecoin Insider. India's Reserve Bank has also flagged concerns that FEMA restrictions create onboarding friction for Indian bank counterparties dealing with USD-backed stablecoin instruments, a regulatory nuance that any institution entering this corridor will need to navigate. A licensed U.S. bank native to onchain settlement could reduce compliance friction on the U.S. side of those flows.
In Nigeria, where naira inflation has exceeded 30 percent, USDT already functions as a practical savings vehicle for millions of people. Sub-Saharan Africa recorded 52 percent crypto adoption growth in 2025, the highest of any region globally, and 51 percent of adults in the region remain unbanked. Global stablecoin transaction volumes now run at roughly $10.9 trillion annually, with individuals in emerging markets holding approximately 66 percent of total stablecoin supply. Cross-border B2B stablecoin payments are projected to reach $5 trillion by 2035.
The caveat is real: OpenReserve has described its initial focus as institutional customers handling treasury management, stablecoin issuance, and tokenized deposits. Direct retail access in Nigeria, India, or Pakistan would require local fintech partnerships or correspondent banking agreements that do not yet exist publicly. Pakistan presents its own set of complications: the country's freelance economy already depends heavily on stablecoin payment rails, but periods on the FATF grey list and ongoing AML screening requirements add meaningful friction for any institution seeking to serve that market at scale. Regulators across both regions are also watching the dollar stablecoin expansion cautiously. The Reserve Bank of India has expressed concern about monetary sovereignty, while the Nigerian government continues to navigate the relationship between widespread USDT adoption and the eNaira CBDC program, which has faced widely reported adoption challenges since its launch.
Developers building cross-border payment applications should monitor whether OpenReserve publishes open APIs and what its stablecoin collateral acceptance policies look like once it files under the GENIUS Act. Those details, not the OCC headline, will determine how much of this charter's potential reaches the corridors that need it most.