Summary of Interpretive Letter 1179 Requests

The Office of the Comptroller of the Currency (OCC) issued three interpretive letters (ILs) in 2020 and early 2021 addressing the permissibility of national banks and Federal savings associations (banks) engaging in certain crypto-asset activities, whether as part of the business of banking or incidental thereto or pursuant to another specified authority, including custody (IL 1170), stablecoin reserve (IL 1172), and distributed ledger technology (DLT) payment (IL 1174) activities. The OCC later required in IL 1179 that banks first notify their supervisory office of their intent to enter into any such activity and should seek a written supervisory non-objection (SNO) prior to doing so. The OCC issued IL 1183 on March 7, 2025, rescinding IL 1179.

The chart below provides a summary of each formal SNO request submitted by an institution supervised by the OCC pursuant to Interpretive Letter 1179 following the publication of IL 1179 on November 18, 2021, and prior to its recission, as well as links to the OCC’s formal responses, where applicable.¹

Proposed Activity	IL Applicability	Date of Initial SNO Request	Status/Date of Response
Holding deposits serving as reserves backing a stablecoin	ILs 1172 and 1179 applied as the bank would be holding deposits serving as reserves backing a stablecoin	1/6/22 (initial request); 3/15/22 (second request)	Insufficient response notice 3/4/22; Withdrawn 3/30/23
Holding deposits serving as reserves backing a stablecoin	ILs 1172 and 1179 applied as the bank would be holding deposits serving as reserves backing a stablecoin	1/20/22	Withdrawn 2/7/23
Provision of crypto asset custody and ancillary services to bank custody clients	ILs 1170 and 1179 applied because the bank would engage in crypto custody	3/30/22	Withdrawn 3/27/23
Beta testing of proposed crypto custody services to be offered as an accommodation to existing bank custody clients	ILs 1170 and 1179 applied because the bank would engage in crypto custody	6/16/22	Withdrawn 6/8/23
Use of an internal blockchain to provide an alternative mechanism for correspondent banks to execute book transfers among their correspondent banking partners using smart contracts	ILs 1174 and 1179 applied because the bank would use DLT to facilitate payments	7/7/22	SNO provided 5/5/23
Use of DLT to facilitate real-time intrabank payments between bank customers	ILs 1174 and 1179 applied because the bank would use DLT to facilitate payments	9/7/22	Insufficient response notice 10/17/22; Withdrawn 1/4/23
One-time wallet-to-wallet transfer to settle a custody client dispute	ILs 1170 and 1179 applied because the bank would engage in crypto custody; rendered moot upon settlement of dispute	12/1/22	Withdrawn 12/20/23
Stablecoin/payment activities involving a consortium and holding an interest in the consortium	ILs 1174 and 1179 likely would apply if/when the bank began to use DLT to facilitate payments; separately, the bank acquired, but then divested itself of, hash tokens	12/16/22	Withdrawn 11/12/24
Holding deposits serving as reserves backing a stablecoin	ILs 1172 and 1179 applied as the bank would be holding deposits serving as reserves backing a stablecoin	12/30/22	Withdrawn 3/16/23
Use of an internal blockchain to facilitate transfer of beneficial ownership interests in money market mutual fund shares that serve as collateral for swaps	ILs 1174 and 1179 applied because the bank would use DLT to facilitate payments	2/14/23 (initial description); 3/7/23 (description of pilot program); 10/9/23 (full launch)	SNO provided 9/19/23 (pilot program) and 10/13/23 (full launch)
Use of an internal blockchain utilizing smart contracts and tokenized deposits to enable a corporate customer to pay its service provider securely and automatically	ILs 1174 and 1179 applied because the bank would use DLT to facilitate payments	2/28/23 (test transactions); 8/4/23 (client-facing pilot transactions); 12/21/23 (expansion)	SNO provided 5/30/23 (test transactions); 9/1/23 (client-facing pilot transactions); 5/3/24 (expansion)
Use of an internal blockchain to provide clients with 24/7 instant availability of funds and enable intercompany payments on a cross-border basis using tokenized deposits issued by the bank	ILs 1174 and 1179 applied because the bank would use DLT to facilitate payments	2/28/23 (test transactions); 8/4/23 (client-facing pilot transactions); 12/21/23 (expansion)	SNO provided 5/30/23 (test transactions); 9/1/23 (client-facing pilot transactions); 5/3/24 (expansion)
Expansion of the bank’s existing use of an internal blockchain to facilitate secured intraday extensions of credit	ILs 1174 and 1179 applied because the bank would use DLT to facilitate payments	4/7/23	SNO provided 11/1/23
Use of an internal blockchain to facilitate delivery vs. payment transfer of funds for beneficial ownership interests in debt securities	ILs 1174 and 1179 applied because the bank would use DLT to facilitate payments	5/4/23	SNO provided 11/17/23
Expansion of the bank’s existing use of an internal blockchain to facilitate intraday repurchase agreement activities	ILs 1174 and 1179 applied because the bank would use DLT to facilitate payments	5/4/23	SNO provided 11/1/23
Provision of traditional custody and settlement services for institutional clients trading on a third-party bond exchange, where that exchange uses permissioned DLT for its own internal registry system	ILs 1170, 1174, and 1179 did not apply, provided that the bank would not directly use DLT nor custody a crypto-asset	5/30/23	Communicated IL 1179 not applicable 8/10/23
Provision of fund accounting and administrative services to foreign-based asset managers who introduce ETFs with digital asset futures as underlying	IL 1179 did not apply as the activities themselves did not involve crypto-asset custody, stablecoins, or DLT and relied on longstanding precedent for their permissibility	5/30/23	Communicated IL 1179 not applicable Q3 23
Engagement in testing/proofs of concept to experiment with a global network of tokenized liabilities (e.g., central bank reserves, commercial bank deposits, etc.)	IL 1179 did not apply; the demo did not involve any live transactions	5/30/23	Communicated IL 1179 not applicable Q1 24
Provision of traditional issuing and paying agent services to issuer clients, where those clients use a third-party clearinghouse’s private permissioned DLT network to issue notes	ILs 1174 and 1179 applied because the bank would use DLT and stablecoins to facilitate payments	6/14/23	SNO provided 8/2/23
Wealth management platform that would include data aggregation, digital asset reference data, valuation date, and statement aggregation for clients’ digital assets held on third-party platforms	ILs 1170, 1174, and 1179 did not apply, provided that the bank would not directly use DLT nor custody a crypto-asset	11/21/23	Communicated IL 1179 not applicable 12/13/23
Expansion of the bank’s existing use of an internal blockchain to facilitate intraday FX swaps	ILs 1174 and 1179 applied because the bank would use DLT to facilitate payments	9/5/24	SNO provided 11/21/24

¹ This table is not intended to be a complete inventory of permissible crypto-asset activities discussed in any of the ILs cited in IL 1179 or otherwise. Each SNO request was specific to the submitting institution. Therefore, institutions should not engage in activities in reliance on this document and instead should review the relevant law, precedent, and OCC guidance before engaging in an activity.