Interpretive Letter 1183: reaffirms crypto custody, stablecoin and node activities; rescinds IL 1179's non-objection requirement

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Interpretive Letter 1183
                                                                               March 2025
                      OCC Letter Addressing Certain Crypto-Asset Activities

                                                  March 7, 2025

        This letter rescinds Interpretive Letter 1179 (November 18, 2021). This letter also
reaffirms that the crypto-asset custody, distributed ledger, and stablecoin activities (hereafter,
“crypto-asset activities”) discussed in prior letters are permissible. Specifically, the OCC issued
three interpretive letters in 2020 and early 2021 addressing whether it is permissible for national
banks and federal savings associations (collectively, “banks”) to engage in crypto-asset
activities. These interpretive letters are:

      •   OCC Interpretive Letter 1170 (July 22, 2020), addressing whether banks may provide
          crypto-asset custody services;
      •   OCC Interpretive Letter 1172 (September 21, 2020), addressing whether banks may hold
          dollar deposits serving as reserves backing stablecoins in certain circumstances; and
      •   OCC Interpretive Letter 1174 (January 4, 2021), addressing whether banks may (1) act as
          nodes on an independent node verification network (i.e., a distributed ledger) to verify
          customer payments and (2) engage in certain stablecoin activities to facilitate payment
          transactions on a distributed ledger.
        Since the issuance of Interpretive Letter 1179, 1 OCC staff have continued to develop
knowledge and expertise regarding crypto-asset activities. Based on this supervisory experience,
the OCC has determined that Interpretive Letter 1179 is no longer necessary. This rescission is
intended to reduce burden, encourage responsible innovation, and enhance transparency. The
rescission will also ensure that bank activities will be treated consistently, regardless of the
underlying technology.

        The OCC will examine the activities described in Interpretive Letters 1170, 1172, and
1174 as part of its ongoing supervisory process. As with any activity, banks must conduct all
crypto-asset activities in a safe, sound, and fair manner and in compliance with applicable law.
New activities should be developed and implemented consistent with sound risk management
practices and align with banks’ overall business plans and strategies.

/s/

Rodney E. Hood
Acting Comptroller of the Currency

1
 Interpretive Letter 1179 outlined a supervisory nonobjection process for banks that seek to engage in the activities
addressed in Interpretive Letters 1170, 1172, or 1174.