OCC Clears National Banks to Hold Crypto on Balance Sheets for Gas Fees

TLDR

• OCC states banks may hold crypto needed to pay blockchain gas fees.

• Interpretive letter 1186 says holdings must support lawful bank activity.

• Banks can use crypto for tests of internal or third-party platforms.

• Rules for stablecoin issuers are still being drafted under the GENIUS Act.

The chief regulator of national banks has confirmed that U.S. banks may now keep crypto assets on their balance sheets for the purpose of paying blockchain network fees. The Office of the Comptroller of the Currency issued the position in interpretive letter No. 1186 on Tuesday. The move gives banks clarity as more financial services begin to use blockchain systems.

The agency said banks may hold the amount of crypto they reasonably expect to need for approved activities. Blockchain networks require the use of native tokens to process transactions, and these fees cannot be avoided when banks operate on such systems. The OCC explained that this need makes the asset holdings permissible under federal banking law.

Guidance Defines Use of Crypto as an Operational Need

The letter stated that paying network fees fits into a long-standing category known as “incidental to the business of banking.” The OCC used this term to show how the activity can support a bank’s normal operations. The agency also compared the situation to past banking needs, such as holding foreign currency or shares in payment systems to process transactions.

Banks may need to hold crypto when they support custody operations or when they act as an agent for customers. The agency also said banks may use the assets when they test internal or third-party crypto platforms. In its words, “Holding crypto for this purpose is permissible when it supports otherwise lawful banking activities.”

The guidance stressed that banks must manage market, liquidity, cybersecurity, legal, and operational risks. The amount of crypto on the balance sheet should remain minimal and should fit within a bank’s capital structure.

Policy Shift Continues Under Current OCC Leadership

The letter comes as the OCC operates under Comptroller Jonathan Gould, who was confirmed in mid-2025. Under Gould, the OCC has taken steps to allow banks to engage in more digital asset activity. The agency had already issued guidance that allowed banks to run nodes on blockchain networks and offer digital asset custody services.

This new letter adds to that trend, and it offers a framework for banks that want to reduce their reliance on outside service providers. It also gives banks more control over the technical parts of blockchain services, since they can now keep the assets needed to carry out transactions.

The OCC said this move supports activities permitted under the Guiding and Establishing National Innovation for U.S. Stablecoins Act. This includes the handling of network fees linked to stablecoin transactions and other approved services.

Regulators Move Toward New Stablecoin Rules

The letter arrives as federal banking agencies work on a new set of rules for stablecoin issuers. These rules are being drafted under the GENIUS Act, though they are not yet in effect. The Federal Reserve, the Federal Deposit Insurance Corp., and the Treasury Department are part of that process.

While those rules develop, the OCC’s guidance offers clarity for banks that are preparing to expand their digital asset operations.

The agency said that paying blockchain fees is a standard part of using these networks, and banks may now hold the assets they expect to need for that purpose.

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