The Office of the Comptroller of the Currency has granted preliminary conditional approval for a national bank charter to OpenReserve Bank, a blockchain native lender built to settle money movement continuously rather than in the overnight batches that still define most of American banking. The approval, issued September 2, is not really a story about one startup. It is a signal that federal regulators are now willing to charter a bank whose core ledger runs on the same always on logic as a public blockchain, provided it still answers to the same capital and supervisory rules as anyone else.
A charter built around continuous settlement
OpenReserve Bank, National Association (in organization) was founded by Dee Choubey and Richard Correia, two former MoneyLion executives who ran that digital bank through its public listing and its 2025 sale to Gen Digital. The charter application was filed with the OCC on April 13 and cleared preliminary conditional approval in just under five months, a fast timeline for a full service national bank charter (OCC Corporate Decision #1389, September 2, 2026).
The conditions attached to the approval are conventional in shape for a de novo bank, even if the numbers are demanding. OpenReserve must raise at least $210 million in initial paid in capital, net of organizational and preopening costs, and maintain a Tier 1 leverage ratio of at least 12 percent for its first three years, more than double the roughly 5 percent minimum that applies to an established institution. Before it can open, the bank still needs the OCC’s final approval, FDIC deposit insurance and Federal Reserve Bank stock, the same sequence every de novo bank has to clear regardless of what its ledger looks like underneath.
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What “continuous” replaces
The pitch is specific about the plumbing it wants to bypass. Instead of routing payments and settlement through ACH batch windows or wire cutoff times, OpenReserve wants its core ledger to move money the way a blockchain settles a transaction: in real time, with the transaction itself standing in as the record. The bank plans to offer deposit and lending products with tokenized capabilities alongside payments, treasury services, digital asset custody and foreign correspondent banking, according to the OCC’s decision.
“Preliminary conditional approval to charter a de novo national bank is a privilege our team does not take lightly. It is a significant milestone and the beginning of the most demanding phase of the work,” said Dee Choubey, co-founder and chief executive of OpenReserve Bank. Richard Correia, the bank’s co-founder and president, framed the target customer around businesses that never stop moving money: “Our prospective customers run global businesses that operate continuously, and there is real capital to unlock.”
Capital lining up behind the thesis
OpenReserve raised a $25 million seed round led by a16z crypto, with Coinbase Ventures, Jump Capital, Acrew and other funds participating. That is a modest sum next to the $210 million in paid in capital the OCC is requiring before the bank can actually open, and it underscores how much institutional capital still has to arrive between a conditional approval letter and a functioning, deposit taking bank. Utah, where the bank plans to be based, has become a routine landing spot for this kind of charter given its industrial bank framework and history with fintech lenders.
Where this fits the broader charter rush
Not every applicant clears the OCC’s bar, and the agency has denied charter applications even as it approved others in the same stretch of weeks. Revolut cleared its own conditional approval around the same time, a reminder that a national charter has become close to table stakes for a scaled consumer fintech rather than a novelty. What separates OpenReserve from that pattern is the ledger design underneath the charter. Most fintechs seeking a charter are asking to keep doing what they already do, lending or payments or custody, without renting a partner bank. OpenReserve is asking regulators to accept settlement infrastructure built more like a public blockchain than a core banking system from an incumbent processor, inside the same supervisory perimeter as any other national bank.
That is also a different path than the one stablecoin issuers have taken. Rather than pursuing a narrow trust charter for custody and issuance, the kind national trust banks have received over the past year, OpenReserve applied for a full service national bank charter, meaning it will eventually take deposits, extend credit and answer to the same safety and soundness exams as any regional bank.
What it means for the finance leader
For a corporate treasurer, the near term change is close to zero. OpenReserve Bank cannot open for business until it clears preopening requirements, secures deposit insurance and raises the balance of its required capital, a process that will likely run well into 2027. The medium term question is more concrete. If a federally chartered, FDIC insured bank can settle payments and lending continuously instead of on ACH’s batch schedule, every incumbent bank’s core processing contract now has an implicit deadline attached to it. Treasury teams renewing banking relationships this cycle should be asking their existing banks when continuous settlement, not simply faster batch cycles, lands on their own roadmap, and pricing that answer into the renewal.
The case for skepticism
A programmable, always on ledger inside a chartered bank also concentrates operational risk in places examiners have not tested at scale. A settlement error or an oracle failure does not wait politely for the next business day to surface, the way a batch file error traditionally would. The OCC’s insistence on a 12 percent Tier 1 leverage ratio, more than double the standard minimum, reads as the agency’s own hedge against a business model it has approved in principle but not yet supervised in production. Whether that capital cushion is enough will not be tested until OpenReserve is actually moving client money at volume, and conditional approval is still a long way from that point.
