OCC: Issued Interpretive Letter 1183, rescinding IL 1179
National banks can now custody crypto and hold stablecoins without a separate non-objection request.
FDIC: Cancelled FIL-16-2022 notification requirement
FDIC-supervised institutions may engage in permissible crypto activities after normal risk-management review.
Federal Reserve: Rescinded Supervisory Letters SR 22-6 and SR 23-8
State-member banks and holding companies no longer need advance notice or formal approval for most crypto-asset services.
Compliance Benefits: Removed regulatory hurdles that previously required advance approvals and lengthy processes.
Market Impact: Enables traditional banks to compete with crypto-fintech firms and reduces compliance costs.
Future Outlook: Regulatory clarity continues with ongoing guidance from the President's Working Group.
On April 24, 2025, the United States took a dramatic step toward normalizing digital‑asset services in traditional finance. The Federal Reserve announced that it was withdrawing the two supervisory letters that had forced banks to ask for prior approval before touching crypto‑assets. That move, echoed by the OCC and the FDIC, effectively ends the era of heavy‑handed crypto banking restrictions that haunted banks for three years.
Before the April decision, banks faced a maze of notifications, non‑objection requests, and joint‑statement compliance checks. The rules created a chilling effect: many regional and community banks stayed out of the crypto market altogether, fearing long approval timelines and costly compliance programs. Removing those barriers does three things:
Date | Regulator | Action Taken | Impact on Banks |
---|---|---|---|
March 7, 2025 | Office of the Comptroller of the Currency (OCC) | Issued Interpretive Letter 1183, rescinding IL 1179 | National banks can now custody crypto and hold stablecoins without a separate non‑objection request. |
March 28, 2025 | Federal Deposit Insurance Corporation (FDIC) | Cancelled FIL‑16‑2022 notification requirement | FDIC‑supervised institutions may engage in permissible crypto activities after normal risk‑management review. |
April 24, 2025 | Federal Reserve Board | Rescinded Supervisory Letters SR 22‑6 and SR 23‑8 | State‑member banks and holding companies no longer need advance notice or formal approval for most crypto‑asset services. |
SR 22‑6 (2022) demanded that state‑member banks send the Fed a heads‑up before starting any crypto‑related activity. SR 23‑8 (2023) added a formal “non‑objection” step, turning every new token service into a mini‑regulatory filing. Together they created a two‑step gate that many banks simply could not clear. With those gone, the path to offering crypto custody, stablecoin deposits, or even participating in independent node verification networks becomes a standard product‑development decision rather than a regulatory hurdle.
The new landscape gives banks three clear buckets of permissible activity:
All activities remain subject to existing safety‑and‑soundness rules, consumer‑protection statutes, and anti‑money‑laundering (AML) obligations. In practice, that means banks will continue to file regular risk‑assessment reports, but they won’t have to submit separate “crypto‑specific” applications.
Legal firms and industry analysts have praised the coordination. Jones Day called the Fed’s move a “softening of stance” that follows the OCC’s lead. The Fintech Law Blog described the shift as a “permissive stance” that eliminates the “regulatory uncertainty” that had stalled many projects. Latham & Watkins highlighted that the OCC’s reaffirmation of crypto‑custody and stablecoin reserve‑holding “represents a clear departure from the restrictive interpretations of the previous administration.”
From a practical standpoint, banks are already drafting product roadmaps. Early‑stage pilots at a handful of regional banks indicate they plan to launch crypto‑wallet services by Q1 2026, and a few larger institutions have announced intentions to offer stablecoin‑linked checking accounts.
Even with the big letters gone, regulators left several gray zones:
All three agencies said they will keep working with the President’s Working Group to flesh out additional guidance. Expect follow‑up releases in late 2025 or early 2026 that address these gaps.
For a bank that wants to act now, a practical six‑step checklist can keep the rollout smooth:
Following this pathway lets banks move quickly while staying within the “normal supervisory processes” that the Fed now emphasizes.
Analysts are already speculating about the broader impact. If traditional banks capture even a modest share of the crypto‑custody market, the total addressable market could add $50‑$70billion in assets under management by 2028. That influx would bring more institutional discipline to the crypto ecosystem and could push stablecoins toward wider acceptance as a “digital dollar.” At the same time, the regulatory vacuum around crypto‑lending could spark a new wave of fintech‑bank partnerships, where banks provide the back‑office compliance while fintechs handle the front‑end user experience.
In short, the 2025 rollback doesn’t just remove paperwork - it opens a gateway for banks to become a mainstream part of the digital‑asset economy.
The Fed withdrew Supervisory Letters SR22‑6 (advance‑notice requirement) and SR23‑8 (non‑objection process). Banks no longer need to file special notifications before offering most crypto‑related services.
Not yet. The current guidance still treats non‑stablecoin tokens as high‑risk. Banks may hold stablecoins, but broader crypto‑asset balance‑sheet treatment will need additional guidance.
Letter1183 removes the requirement for a “supervisory non‑objection” before banks engage in crypto custody, stablecoin holdings, or node participation, effectively treating these activities like any other banking service.
Yes. The FDIC’s new guidance says institutions may proceed without prior approval, but they must still manage risks and comply with AML and consumer‑protection rules, which are reviewed in regular supervisory exams.
Key gaps include guidance on crypto‑lending, balance‑sheet treatment of non‑stablecoin assets, and cross‑border token services. Expect further clarification from the President’s Working Group later this year.