On March 7, 2025, the Office of the Comptroller of the Currency (OCC) published Interpretive Letter 1183, which rescinded prior guidance on digital assets and reaffirmed other interpretative letters confirming that crypto-asset activities are permissible in the federal banking system. Specifically, Interpretative Letter 1183 reaffirmed that banks may
- provide crypto-asset custody services (Interpretive Letter 1170),
- hold dollar deposits as reserves backing stablecoins in particular circumstances (Interpretative Letter 1172),
- act as nodes on an independent node verification network (i.e., a distributed ledger) to verify customer payments and engage in certain stablecoin activities to facilitate payment transactions on a distributed ledger (Interpretative Letter 1174).
Further, Interpretive Letter 1183 rescinds Interpretive Letter 1179, which required each bank to seek approval from its supervisory office before engaging in the aforementioned cryptocurrency activities.
Takeaway
The issuance of this new guidance is another step in the administration’s shift towards digital assets. Interpretive Letter 1183 promotes the lawful use by companies and institutions for investments in digital assets by providing regulatory clarity for federal banks and streamlining the permitted activities of federal banks. Along with the repeal of SEC Staff Accounting Bulletin 121, this interpretive letter opens the door for traditional financial institutions to invest in digital assets and will likely promote the development of new products involving such assets.
