OpenReserve Bank, a proposed national bank built on proprietary blockchain technology, has received conditional approval from the Office of the Comptroller of the Currency (OCC). The bank, founded by two former MoneyLion executives, aims to merge traditional banking with digital-asset services, including tokenized deposits and a future stablecoin. The OCC’s decision letter, released Thursday, also outlines significant capital requirements and a $25 million seed funding round led by Andreessen Horowitz.
What OpenReserve Bank Plans to Offer
OpenReserve Bank intends to serve institutional clients with a unified on-chain ledger, enabling instant payments and asset financing. The bank’s proposed services include:
- Tokenized deposits that function on a blockchain ledger.
- A banking-as-a-service platform, a first for OCC-approved banks.
- A stablecoin issuing subsidiary, planned to launch a dollar-backed stablecoin called ReserveUSD.
The OCC’s decision letter notes that the stablecoin subsidiary application has not yet been filed, but co-founder and proposed CEO Dee Choubey confirmed that the application will be submitted soon. The stablecoin is designed to comply with the GENIUS Act, a U.S. regulatory framework for stablecoins.
Regulatory Significance and Industry Context
OpenReserve is the latest in a series of digital banks to receive conditional OCC approval, following Augustus Bank earlier this year. The OCC also approved SoFi’s stablecoin subsidiary on the same day. According to Roman Goldstein, senior director at Klaros Group, this trend signals a regulatory shift toward treating stablecoins and tokenized deposits as interchangeable, a concept central bankers call the ‘singleness of money.’
Goldstein noted that the OCC appears to be ‘breaking down the distinction between bank deposits and stablecoins,’ which could lead to a more unified digital asset ecosystem. The inclusion of banking-as-a-service in OpenReserve’s charter is also seen as a novel development, reflecting revised regulatory thinking.
Capital Requirements and Next Steps
OpenReserve Bank must meet specific conditions before commencing operations. The OCC’s decision letter sets initial capital requirements at no less than $210 million, with a tier 1 leverage ratio of at least 12.0%. Choubey acknowledged that these requirements are ‘on the larger side’ for a de novo bank but are intentional as part of the bank’s strategy.
In addition to OCC approval, OpenReserve must obtain clearance from other regulators, including the Federal Deposit Insurance Corporation (FDIC). The bank’s leadership team includes former MoneyLion board chairman John Chrystal, former OCC advisor Jame Sloan, and former Robinhood security chief David Schwed.
Funding and Leadership
The bank announced a $25 million seed funding round led by Andreessen Horowitz, with participation from Coinbase Ventures, Jump Capital, Acrew, and Zero Knowledge Ventures. Co-founder and proposed president Richard Correia emphasized that the bank aims to unlock capital for global businesses by offering a unified on-chain ledger where payments settle instantly and assets can be financed against the same ledger.
Choubey and Correia began developing OpenReserve after MoneyLion’s acquisition by Gen Digital last year. The conditional approval marks a significant milestone, but the bank must satisfy all regulatory conditions before opening its doors.