OpenReserve wins a US bank charter priced at $210m and 12%

The Office of the Comptroller of the Currency granted OpenReserve Bank, National Association a preliminary conditional approval on September 2, 2026, and priced the charter at $210 million of initial paid-in capital plus a tier 1 leverage ratio of no less than 12.0 percent for three years. Set against the OCC's own 2026 record, the dollar figure is unremarkable. The leverage floor is the number that carries the supervisory judgment. I read the capital section of every full-service de novo national bank decision the OCC published this year. Eight letters, eight figures: $507 million for Itaú Bank, $504 million for Nubank, $404.1 million for Upstart Bank, $300 million for Mercury Bank, $210 million for OpenReserve, $95 million for Revolut Bank US, $52.5 million for Augustus National Bank and $25 million for VALT Bank. OpenReserve's $210 million ranks fifth of the eight and sits below the $255 million midpoint of that set. On dollars, the OCC treated OpenReserve as an ordinary de novo. Twelve percent is a balance-sheet band, not a penalty The leverage condition is where the file separates. The 2026 floors run 8.0 percent for Itaú, 9.0 percent for VALT, 10.0 percent for Mercury, Augustus and Revolut, 11.0 percent for Nubank, and 12.0 percent for Upstart and OpenReserve. Twelve is the ceiling of the observed range, and OpenReserve is not alone at it: Upstart carries the same 12.0 percent floor plus a total risk-based capital ratio of no less than 15 percent, a second constraint OpenReserve did not receive. Erebor Bank, approved in October 2025 with a stablecoin and distributed-ledger payments plan, also sits at 12 percent. What the 12 percent cohort shares is a balance sheet that holds something other than loans and cash. Corporate Decision #1389 says OpenReserve 'will also hold an amount of digital assets on its balance sheet it expects are needed to pay transaction fees for on-chain transactions,' takes fees in kind out of customer trades and staking rewards, and 'plans to form a wholly-owned stablecoin subsidiary to engage in issuance, custody, conversion, and payment of U.S. dollar-denominated reserve-backed stablecoins.' The comparator letter issued the same day records the opposite posture — that bank 'does not intend to hold any digital assets on its balance sheet' and projects digital-asset revenue below 2 percent of the total over the de novo period. The Industry Spread covered that decision and its retail forex carve-out on September 4. MoneyLion's top three, reassembled The applicant is also not unknown. OpenReserve's organizers include Diwakar Choubey as chief executive and Richard Correia as president and chief operating officer. MoneyLion's 2023 proxy statement lists the same two men as, respectively, chief executive officer and 'President, Chief Financial Officer and Treasurer' of the Nasdaq-listed lender, and records that Choubey 'co-founded MoneyLion in 2013.' A third organizer and director, John Chrystal, chaired MoneyLion's board and served as a director of The Bancorp from June 2013 to February 2022, including as vice chairman from April 2017 — sponsor-bank experience that maps directly onto OpenReserve's stated plan to run a 'full-service banking-as-a-service platform.' That plan is the reason the capital number reads the way it does. OpenReserve intends to offer 'tokenized capabilities across all deposit products,' payments and treasury services, digital asset custody and foreign correspondent banking, from a Salt Lake City main office with no branches. A charter that combines BaaS distribution with correspondent banking and an issuing stablecoin subsidiary is not one balance sheet; it is three, and the OCC condition set reflects that. Condition one requires OpenReserve to conform its activities, 'including stablecoin issuance,' to the GENIUS Act, 'such compliance to be determined in the sole discretion of the OCC.' Utah, and the odds of opening Salt Lake City is now the address of two 2026 national bank approvals. Mercury Bank, owned by Mercury Technologies, was approved on April 24 with a main office there and, like OpenReserve, 'no physical branch.' The national charter route gives both firms something a Utah industrial bank charter cannot: Federal Reserve membership and direct payments-system access. Both letters record the understanding that the bank 'will apply for stock in a Federal Reserve Bank' and obtain FDIC insurance. Preliminary conditional approval is not a charter. Both September 2 letters give organizers 12 months to raise the capital and 18 months to open, and Senior Deputy Comptroller Stephen A. Lybarger notes the OCC 'is opposed to granting extensions.' Conversion is far from automatic — as we reported, only two of the OCC's five crypto trust charters have actually opened. Expect OpenReserve's $210 million raise, not the 12 percent floor, to be the binding constraint through mid-2027, and expect the next digital-asset applicant to model 12 percent from day one. Nubank's separate licence purchase in Brazil shows the alternative when organic chartering looks slow.