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OCC Confirms Bank Authority to Hold Crypto-Assets as Principal for Paying Network Fees

By A.J. Dhaliwal, Mehul Madia & Maxwell Earp-Thomas on November 26, 2025
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On November 18, the OCC issued Interpretive Letter 1186 confirming that a national bank may, as an activity incidental to the business of banking, pay crypto-asset network fees to support otherwise permissible banking activities. The letter also states that a bank may hold, as principal, limited amounts of crypto-assets on its balance sheet when needed to cover these fees. In addition, the OCC confirmed that banks may hold small quantities of crypto-assets as principal for purposes of testing crypto-asset platforms.

The OCC framed these activities as a modern extension of established bank powers, emphasizing that limited principal holdings can support operational efficiency and customer transactions when tied to foreseeable network-fee needs. The agency noted that these activities must remain de minimis, risk-controlled, and integrated into existing compliance and oversight programs.

Putting It Into Practice: Federal regulators continue to clarify the scope of permissible digital-asset activities (previously discussed here and here). Banks considering distributed-ledger integrations should reassess network-fee dependencies, confirm that any crypto-asset holdings remain de minimis and purpose-driven, and update internal controls and governance frameworks accordingly. Financial institutions should continue monitoring federal and state supervisory developments as digital-asset requirements evolve.

Photo of A.J. Dhaliwal A.J. Dhaliwal

A.J. is a partner in the Finance and Bankruptcy Practice Group in the firm’s Washington, D.C. office.

Read more about A.J. DhaliwalEmail
Photo of Mehul Madia Mehul Madia

Mehul Madia, special counsel in the firm’s Washington, D.C. office, provides deep consumer finance and fintech expertise to clients, leveraging more than 15 years’ of public and private sector experience.

Read more about Mehul MadiaEmail
Photo of Maxwell Earp-Thomas Maxwell Earp-Thomas

Max is an associate in the Finance & Bankruptcy Practice Group in the firm’s Orange County office.

Read more about Maxwell Earp-ThomasEmail
  • Posted in:
    Banking, Finance and Securities
  • Blog:
    Consumer Finance and Fintech Blog
  • Organization:
    Sheppard, Mullin, Richter & Hampton LLP
  • Article: View Original Source

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