US OCC Interpretive Letter 1186 Bank Crypto-Asset Network Fees

The letter focuses on transaction fees charged by distributed ledger technology networks. The OCC explains that some blockchain networks require users to pay a network fee to incentivize nodes to validate transactions and add them to the blockchain. It also notes that fees may be dynamically calculated and may have to be paid in the network’s native crypto-asset, even where a transaction involves another token on that network.

This matters for bank crypto-asset services because a bank providing custody, transfer, settlement, or related services may need to complete on-chain transactions. The OCC’s analysis treats paying network fees, and holding limited crypto-assets to pay those fees, as incidental to otherwise permissible banking activity where the bank has a reasonably foreseeable need.

• Network-fee payments: A national bank may pay network fees on blockchain networks to facilitate otherwise permissible activity.
• Principal holdings for gas fees: A bank may hold crypto-assets on balance sheet, as principal, when necessary to pay network fees for which it anticipates a reasonably foreseeable need.
• Platform testing: A bank may hold crypto-assets as principal to test otherwise permissible crypto-asset-related platforms, whether internally developed or acquired from a third party.
• Operating subsidiaries: The OCC states that the permissibility analysis applies equally to national banks and their operating subsidiaries.
• Risk controls: The letter relies on the bank’s representations that it will conduct risk and compliance assessments and address operational, market, liquidity, and compliance risks.

For U.S. crypto law coverage, Interpretive Letter 1186 is important because it narrows a practical operational question for OCC-regulated banks: whether a bank can hold native crypto-assets needed to pay on-chain transaction fees without treating those holdings as a standalone speculative crypto position. The OCC’s analysis emphasizes customer facilitation, operational efficiency, and incidental banking powers under the National Bank Act rather than creating a broad investment authority.

The letter is not a statute and does not replace other legal regimes. It responds to the facts of a specific request and states that it does not address whether other activities related to holding crypto-assets as principal are part of the business of banking. It also states that the OCC will examine the activities described in the letter through its ongoing supervisory process.

As of June 4, 2026, this profile should treat OCC Interpretive Letter 1186 as published OCC interpretive guidance, not enacted legislation. Later OCC materials continued to cite IL 1186 in applying bank digital-asset activity analysis, including a May 2026 corporate decision discussing on-balance-sheet digital assets for gas-fee needs.