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OCC approval does not make crypto holdings FDIC-insured. The Office of the Comptroller of the Currency’s 2025 interpretations confirm that national banks and federal savings associations may provide specified crypto custody, stablecoin-reserve, distributed-ledger payment and customer-directed execution services. Those interpretations define what banks are allowed to do; they do not turn a cryptocurrency, stablecoin, or claim on a nonbank app into an insured deposit.

To know what protection you have, classify the balance first: an ordinary deposit at an insured bank, crypto held in custody, a stablecoin claim on an issuer, or money owed by a nonbank intermediary. Only the first category is ordinarily covered by FDIC deposit insurance, subject to ownership-category limits.

What the OCC changed in 2025

Interpretive Letter 1183: custody, reserves and payment activity

On March 7, 2025, the OCC issued Interpretive Letter 1183. It reaffirmed that national banks and federal savings associations may provide crypto-asset custody, hold dollar deposits that serve as stablecoin reserves in certain circumstances, and use distributed-ledger or stablecoin activities to facilitate permissible payments. The letter also rescinded Interpretive Letter 1179’s supervisory non-objection process. Banks no longer need that separate non-objection step for activities covered by the clarified interpretations, but they still must operate within their legal authority and manage the associated risks.

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Acting Comptroller Rodney E. Hood summarized the supervisory standard: “The OCC expects banks to have the same strong risk management controls in place to support novel bank activities as they do for traditional ones.” Permission to offer a service is therefore not a safety rating, an investment endorsement, or a promise that customers will be repaid if a crypto asset loses value.

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Interpretive Letter 1184: customer-directed trading and outsourcing

On May 7, 2025, Interpretive Letter 1184 confirmed that a bank may buy and sell crypto-assets held in custody when the customer directs the transaction. A bank may also outsource permissible custody or execution functions, provided it performs appropriate third-party risk management. The customer can still face the operational, legal and insolvency risks of a service provider even when a regulated bank is involved.

The July 2025 interagency statement

On July 14, 2025, the OCC, Federal Reserve and FDIC issued a joint statement on crypto-asset safekeeping. It said banks providing safekeeping must operate safely and soundly and comply with applicable law; it did not create new supervisory expectations. The agencies noted that the market and its underlying technology are evolving and emphasized a risk-management framework for those risks.

Identify what your balance legally is

The same app can display dollars, coins and tokens in one dashboard, but the legal treatment differs by product. Ask who owes you money and what contract governs the balance.

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Customer balance Who owes the customer What the bank or provider does Typical FDIC treatment
Checking, savings, money-market deposit or CD The insured depository institution named on the account Holds funds as a deposit and records the depositor’s ownership category Generally eligible, up to applicable limits, if the institution is FDIC-insured
Crypto held in custody The custody provider owes safekeeping services; the asset remains a crypto asset Controls wallets, private keys, transfers and records on the customer’s behalf Crypto itself is not an insured deposit; price and loss risks remain
Stablecoin The stablecoin issuer owes redemption under its terms May hold reserve assets, including dollar deposits, and process issuance or redemption Stablecoin holders do not automatically receive FDIC insurance on reserve deposits
Balance at a nonbank intermediary or neobank The nonbank’s contract determines the claim May connect to a partner bank, payment processor or custodian Coverage depends on whether funds are actually qualifying deposits and on recordkeeping; it does not insure the nonbank’s bankruptcy

How FDIC insurance applies

The $250,000 limit

FDIC guidance states that the standard maximum deposit insurance amount is $250,000 per depositor, per FDIC-insured bank, per ownership category. The amount is not a blanket limit for everything a customer owns at a financial-technology company. Deposits in different ownership categories, such as individual and qualifying joint accounts, are analyzed under separate rules, while accounts at the same bank in the same category are generally combined for the limit.

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What is ordinarily covered

Qualifying checking, savings, money-market deposit accounts and certificates of deposit at an FDIC-insured bank can receive deposit insurance. The insured institution, account title, ownership records and applicable category determine the coverage. A bank’s use of a blockchain, tokenized ledger or stablecoin infrastructure does not by itself remove a qualifying deposit from the deposit-insurance framework.

What is not covered

FDIC insurance does not cover cryptocurrency, a custodial wallet balance, a token’s market value, a stablecoin redemption promise or an investment account simply because a bank provides a related service. If a custodian loses private keys, suffers a cyberattack or becomes insolvent, deposit insurance does not reimburse the crypto asset.

Why a “bank partner” label is insufficient

FDIC consumer guidance says, “The FDIC only insures your money if it is in a deposit account at an FDIC-insured bank.” A nonbank app can advertise a relationship with an insured bank while holding some customer funds elsewhere, mixing funds, or owing customers a contractual balance of its own. Coverage depends on where the money is actually held, whether it is a qualifying deposit, and whether records identify each owner. Even when a deposit is insured, that protection addresses the insured bank’s failure; it does not guarantee the nonbank intermediary’s obligations or keep its platform operating.

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Stablecoin reserves and the 2026 FDIC proposal

Stablecoins are claims issued by a company or other issuer, not bank deposits in the holder’s name. An issuer may place dollars in reserve accounts at banks, but the reserve account and the stablecoin holder’s claim are legally different relationships.

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On April 7, 2026, the FDIC approved a proposed rule implementing the GENIUS Act. The proposal would state that deposits backing payment stablecoins are not insured to stablecoin holders on a pass-through basis. In other words, a holder would not automatically inherit FDIC coverage merely because the issuer placed reserve dollars at an insured bank. The proposal would treat qualifying tokenized deposits like other deposits, but the text remains a proposal and may change before a final rule takes effect.

Until the rule is finalized, read the issuer’s redemption, reserve, bankruptcy and custody disclosures rather than relying on the word “stable.” A stablecoin can be designed to track one dollar and still face a run, delayed redemption, counterparty failure or market disruption.

What a bank may do for a crypto customer

Safekeeping

A bank can hold crypto for a customer, maintain wallet infrastructure, safeguard private keys and process authorized transfers. The custody agreement should explain whether assets are held in segregated wallets, how records are reconciled, who can approve transactions, and what happens if the bank or a subcontractor fails. Legal ownership and withdrawal rights come from that agreement, not from the bank’s OCC charter alone.

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Customer-directed execution

Under Letter 1184, the bank may buy or sell crypto held in custody when the customer instructs it to do so. The bank is executing an instruction, not guaranteeing the price, liquidity or suitability of the asset. Confirm when an instruction becomes final, which venue or counterparty is used, how errors are corrected and whether the bank can pause activity for fraud, sanctions or operational reasons.

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Stablecoin reserve services

A bank may hold dollar deposits that serve as reserves for a stablecoin in circumstances allowed by its authority and agreements. That service supports the issuer’s obligations; it does not make each stablecoin holder a depositor at the reserve bank. Reserve composition, withdrawal rights, permitted investments and insolvency treatment should be stated in the issuer and reserve-account documents.

Distributed-ledger payments

Banks may use distributed-ledger technology and stablecoin arrangements to facilitate permissible payments. The technology can change how a payment is recorded or settled, but ordinary requirements still apply: customer identification, anti-money-laundering controls, sanctions screening, transaction monitoring, records and consumer-protection obligations.

Outsourced custody or execution

Outsourcing does not transfer the bank’s responsibility to manage third-party risk. A bank should assess a vendor’s financial condition, security, resilience, subcontractors, access controls, incident reporting and exit plan. Customers should determine which entity actually holds keys, executes trades, maintains records and responds to a withdrawal request.

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Checks to perform before using a bank crypto product

  1. Find the legal entities. Read the account agreement, custody agreement and privacy notice. Write down the exact insured depository institution, the nonbank platform, the crypto custodian, the execution venue and the stablecoin issuer, if applicable.
  2. Classify every balance. Separate dollars in a deposit account from crypto in custody, stablecoins, tokenized deposits and amounts payable by an intermediary. Do not treat a single displayed total as one insured balance.
  3. Verify insurance language. Look for the bank’s FDIC-insured status and the account’s ownership category. Ask whether the funds are held as deposits at that bank, whether records identify you as the owner and what limits apply. A logo or “banking services provided by” statement is not enough.
  4. Read custody and insolvency terms. Check whether assets are segregated, whether the provider may rehypothecate or lend them, how liens are handled, and how you can retrieve assets after termination, bankruptcy or a cyber incident.
  5. Understand keys and approvals. Identify who controls private keys, whether transactions require multiple approvals, how replacement keys are created, and what recovery process applies if an employee, device or vendor is compromised.
  6. Check execution details. For customer-directed buying and selling, review fees, spreads, order timing, supported assets, transfer holds, withdrawal limits and the circumstances in which the bank can reject or delay an instruction.
  7. Assess stablecoin redemption. Confirm who redeems the token, the required identity checks, settlement time, fees, reserve disclosures and what happens during a suspension or issuer insolvency.
  8. Review complaints and incident procedures. The agreement should provide a contact channel, escalation path, error-resolution process and notice obligations after a security or service outage.
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Practical examples

Checking account plus crypto custody at one bank

Suppose a customer has $180,000 in an individual checking account and $70,000 worth of bitcoin in custody at the same insured bank. The checking balance is evaluated for deposit insurance. The bitcoin is a custodial crypto asset and is not added to the insured deposit calculation or protected against a decline in price.

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Stablecoin backed by a bank reserve account

An issuer can keep dollars in a reserve account while customers hold the issuer’s stablecoin. The reserve account belongs to the issuer or the arrangement specified in the contract; the customer owns a redemption claim. Under the FDIC’s April 2026 proposal, that structure would not pass FDIC insurance through to stablecoin holders.

Nonbank app that advertises an insured partner

If an app fails, the customer’s recovery depends on whether the customer owned a qualifying deposit at the partner bank or only had a contractual claim against the app. Records, account terms and the actual movement of funds determine the answer. Deposit insurance does not make the app’s other obligations or its bankruptcy risk disappear.

Tokenized deposit

A token representing a deposit may qualify for the same treatment as another deposit if the final legal structure meets applicable requirements. The label “tokenized” is not enough; the issuing bank, account records, ownership rights and final regulatory rules control.

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Risks banks must manage

  • Key and custody risk: loss, theft or unauthorized use of private keys can prevent delivery of the customer’s asset.
  • Cybersecurity and resilience: wallets, APIs, ledger nodes and vendor connections need access controls, monitoring, backups and tested recovery procedures.
  • Liquidity and redemption: stablecoin issuers and their banks must be able to meet permitted redemptions and manage settlement timing.
  • Anti-money-laundering and sanctions: distributed-ledger transfers require transaction monitoring, identity controls and screening appropriate to the activity.
  • Consumer protection: disclosures should distinguish deposits from crypto, explain fees and conflicts, and describe complaint and error handling.
  • Third-party concentration: dependence on one custodian, cloud provider, execution venue or reserve bank can create a single point of failure.
  • Legal and recordkeeping risk: ownership, liens, segregation and insolvency rights must be documented and reconciled across the bank and every vendor.

What OCC authority does not promise

OCC interpretations do not promise that a token will hold its value, that a stablecoin will always redeem for one dollar, that a custodian will never be hacked, or that every crypto product offered by a bank is insured. They also do not eliminate rules that may apply to state-chartered banks, broker-dealers, exchanges, payment companies or individual products. Those businesses can involve different regulators and contractual protections.

The customer’s safest starting point is therefore the legal category and the named obligor. Confirm whether your money is a qualifying deposit, identify the ownership category and limit, and treat custody, stablecoin and nonbank claims as separate exposures even when one bank provides the technology or service.

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