OCC — National Bank Digital Asset Activities and the SAB 121 Reversal
The OCC granted the only federal bank charter to a crypto institution (Anchorage Digital, 2021) and issued landmark interpretive letters in 2020-2021 authorizing national banks to provide crypto custody, hold stablecoin reserves, and use blockchain for payment activities.
SAB 121 — Staff Accounting Bulletin on Crypto Custody
SEC Staff Accounting Bulletin 121 (March 2022) required entities holding crypto in custody to recognize both an asset and an equivalent liability on their balance sheet, effectively doubling the capital cost of bank crypto custody — a burden reversed by SEC leadership in January 2025.
Wyoming SPDI — Special Purpose Depository Institution
The Wyoming Special Purpose Depository Institution charter creates a bank category that can hold digital assets in custody for clients without engaging in fractional reserve banking — the first US regulatory framework purpose-built for crypto asset custody.