OCC permission is not deposit insurance. The Office of the Comptroller of the Currency’s 2025 interpretations confirm that national banks and federal savings associations may provide specified crypto custody, stablecoin-reserve, distributed-ledger payment, and customer-directed trading services. They do not turn crypto into a bank deposit, guarantee a token’s value, or make a stablecoin claim FDIC-insured. For a customer, the decisive question is what legal product holds the money: an insured deposit, crypto in custody, a stablecoin claim, or an obligation of a nonbank intermediary.
What the OCC changed in 2025
The OCC supervises national banks and federal savings associations. Its interpretive letters explain how existing banking authority applies to new activities; they are not a blanket approval of every crypto product or a promise that a particular bank is safe from loss.
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Interpretive Letter 1183: custody, reserves and payment activity
On March 7, 2025, OCC Interpretive Letter 1183 reaffirmed that national banks and federal savings associations may provide crypto-asset custody, hold dollar deposits that serve as stablecoin reserves in certain circumstances, and use distributed-ledger and stablecoin activities to facilitate permissible payments. The letter also rescinded the supervisory non-objection process associated with Interpretive Letter 1179. Banks no longer need that specific non-objection before conducting activities that are otherwise permissible, but they still must comply with applicable law and maintain effective risk controls.
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Interpretive Letter 1184: customer-directed execution
On May 7, 2025, Interpretive Letter 1184 confirmed that a bank may buy and sell crypto-assets held in custody when a customer directs the transaction. A bank may also outsource permissible custody or execution functions, provided it manages the risks of the third party. The customer therefore may see a bank interface that routes a trade or uses a specialist custodian, but the bank remains responsible for appropriate oversight of the arrangement.
Four balances that customers commonly confuse
A single app can display dollars, tokens and transaction history together even though the legal rights differ. Identify which of these categories contains your balance before assuming any protection.
| What you hold | Who owes or controls it | Ordinary FDIC treatment | Main question to ask |
|---|---|---|---|
| Checking, savings, money-market deposit or CD | An FDIC-insured depository institution | Qualifying deposits are insured up to the applicable ownership-category limit | Is the account actually at the named insured bank, and in whose ownership category? |
| Crypto held in custody | The custodian safeguards private keys or assets for you | Crypto assets are not deposits and are not covered by deposit insurance | How are assets segregated, who controls the keys, and what happens if the custodian fails? |
| Stablecoin | The token issuer owes redemption or other contractual value | Holding the token does not ordinarily make the holder an insured depositor | What backs the token, who can redeem it, and what legal claim exists in an insolvency? |
| Balance with a nonbank intermediary | An exchange, payment company, neobank or other intermediary | Insurance depends on funds being held as qualifying deposits; the intermediary’s own failure is not insured | Which bank holds the funds, under what account structure, and is the balance eligible for pass-through treatment? |
The FDIC states in consumer guidance: "The FDIC only insures your money if it is in a deposit account at an FDIC-insured bank." The usual standard maximum is $250,000 per depositor, per insured bank, per ownership category, under FDIC guidance issued in 2022. That limit applies to qualifying deposits, not to the market value of crypto or to a token merely because its reserves sit at a bank.
What OCC authority does not promise
- No price protection: Bitcoin, other crypto-assets and stablecoins can lose value. OCC authority does not set a floor price or guarantee redemption.
- No automatic FDIC coverage: A custody account, token balance or crypto transaction is not transformed into a deposit by being offered through a bank.
- No approval of every product: A bank must determine that its activity is legally permissible and operate it safely. The interpretive letters do not certify a particular app, token or service.
- No protection from operational loss: Insurance does not cover losses caused by a token’s market movement, a failed trade, theft of a private key or a contract that creates no insured deposit.
- No immunity for vendors: When a bank outsources custody or execution, the bank must manage third-party risk, but the customer should still read the custody and failure provisions in the agreement.
How deposit insurance works in a crypto-related product
Find the insured institution
Start with the legal name of the depository institution, not the name of the app or front-end service. Review the account agreement, disclosures and statements for the bank’s name and FDIC status. If the documents only describe a payment balance, stored value or custodial wallet, do not assume it is a deposit.
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Check the ownership category and aggregate balances
The $250,000 standard maximum is measured per depositor, per insured bank, per ownership category. Deposits at the same bank in the same ownership category are generally aggregated for the limit. A separate brand or interface does not create a separate insured bank. Joint, individual, trust and certain retirement accounts can have different ownership rules, so use the account agreement and FDIC guidance for the specific structure.
Separate cash from tokens
An account may contain both dollars and crypto. The dollar portion can be a deposit while the token portion is a custodial asset or a contractual claim. Ask for a statement that identifies the legal status of each balance rather than relying on a single total shown on screen.
Why a bank partner does not automatically protect a nonbank balance
A crypto company or neobank may advertise that it works with an FDIC-insured bank. That relationship alone does not insure every dollar displayed in the company’s account. FDIC protection depends on whether the funds are actually placed in a qualifying deposit account at the insured institution and, when an intermediary is involved, whether the records and ownership structure satisfy pass-through requirements.
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Stablecoin reserves are not the same as insured stablecoins
OCC Letter 1183 allows a national bank or federal savings association, in certain circumstances, to hold dollar deposits that serve as reserves for a stablecoin. That describes the bank’s reserve activity. It does not make every stablecoin holder a depositor of the reserve bank. The holder’s rights generally arise from the issuer’s token terms and applicable law.
The FDIC’s April 2026 proposal
On April 7, 2026, the FDIC approved a proposal to implement the GENIUS Act. The proposal would provide that deposits backing payment stablecoins are not insured to stablecoin holders on a pass-through basis. It would treat qualifying tokenized deposits like other deposits. The proposal remains subject to change, so its treatment should not be presented as a final rule or as current coverage for a particular token.
For a stablecoin user, review the issuer’s redemption promise, reserve composition, bankruptcy treatment, fees, suspension rights and governing jurisdiction. A reserve account can support confidence in redemption without creating an FDIC-insured claim in the holder’s name.
Safekeeping and custody controls customers should examine
The OCC, Federal Reserve and FDIC issued an interagency crypto-asset safekeeping statement on July 14, 2025. It says banks providing crypto safekeeping must operate safely and soundly and comply with applicable law; it creates no new supervisory expectations. The agencies also recognized the evolving crypto-asset market, its underlying technology and the need for a risk-management framework.
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Translate that principle into specific questions before moving assets:
- Asset segregation: Are customer assets recorded separately from the bank’s or custodian’s own assets, and are commingling rules disclosed?
- Private-key governance: Who generates, stores and can authorize use of keys? Are multiple approvals required for transfers?
- Recovery and loss procedures: What happens after a lost key, mistaken address, unauthorized transfer or service outage?
- Cybersecurity: Which controls protect signing systems, administrator accounts and transaction approvals?
- Reconciliation: How often are on-chain holdings matched to customer records, and who performs independent checks?
- Third-party oversight: If another firm performs custody, trading or technology functions, what audits, service-level terms and termination plans apply?
- Compliance: How are anti-money-laundering, sanctions, privacy and consumer-protection requirements handled?
These controls reduce operational and fraud risks; they do not convert a crypto asset into an insured deposit.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What a customer-directed crypto trade means
Under Letter 1184, a bank can execute a purchase or sale when the customer directs it and the crypto is held in custody. The customer should distinguish three roles in the trade:
- Custodian: Holds or controls the asset and maintains the custody record.
- Executing party: Matches or routes the order and settles the transaction.
- Customer: Gives the instruction and bears the market result under the agreement.
Before placing an order, check whether the bank acts as agent or principal, how prices and spreads are disclosed, when an order becomes final, whether assets can be withdrawn, and which entity handles complaints. Outsourcing can be permissible, but it adds a third-party dependency that should be visible in the contract.
A practical checklist before using a bank-linked crypto service
- Write down what you are buying: a deposit, a custodial token, a stablecoin or a claim against an intermediary.
- Identify the legal counterparty for each balance and obtain the full account, custody and token agreements.
- Verify the name of the FDIC-insured bank, if one is involved, and confirm where dollars are held.
- Calculate deposits at that bank by ownership category, including balances held through other services.
- Read the insolvency section: determine whether you own specific assets, have a general claim, or depend on pass-through records.
- Review custody controls, withdrawal limits, key management, insurance exclusions and incident-notification procedures.
- Ask which vendors execute trades or store keys and how the bank supervises them.
- Keep cash needed for bills in a clearly identified insured deposit account rather than assuming a crypto balance has the same protection.
- Save statements and confirmations showing the asset type, quantity, legal owner and institution holding it.
How the rules differ by institution and product
The 2025 OCC letters address national banks and federal savings associations. A state-chartered bank may be subject to state banking law and oversight by a state regulator, in addition to federal rules. Broker-dealers, exchanges, payment companies and individual token issuers can bring separate regulatory regimes and contractual protections. Therefore, the same label—such as "crypto account"—can describe materially different rights.
| Decision point | Why it matters | Evidence to request |
|---|---|---|
| Legal status | Determines whether deposit insurance can apply | Account opening disclosures and product terms |
| Counterparty | Shows whom you must rely on in a failure | Named bank, custodian, issuer and intermediary |
| Insurance limit | Coverage depends on bank, ownership category and records | FDIC disclosures and balance-allocation records |
| Operational controls | Keys, segregation and cybersecurity affect loss risk | Custody policy, incident process and vendor disclosures |
| Rule status | Final interpretations differ from proposed rules | OCC letters, interagency statements and current FDIC rule text |
Bottom line for depositors and crypto users
The OCC’s 2025 interpretations make it clearer that national banks and federal savings associations can support several crypto activities, including custody, certain stablecoin-reserve arrangements, distributed-ledger payments and customer-directed execution. The rescission of the old non-objection process changes supervision, not the basic distinction between a bank deposit and a crypto asset.
If your balance is a qualifying deposit at an FDIC-insured bank, the standard maximum is $250,000 per depositor, per insured bank, per ownership category. If it is crypto in custody, a stablecoin, or money owed by a nonbank intermediary, OCC authority does not supply that insurance. Confirm the legal category, institution, ownership records and failure provisions before treating a crypto-related balance as protected cash.
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