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On September 21, 2020, the OCC issued Interpretive Letter 1172, which recognized that stablecoin issuers may desire to place their cash reserves in a reserve account with a bank to provide assurance that the issuer has sufficient assets backing the stablecoin in certain situations.
In its Interpretive Letter #1170 issued on July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued a legal interpretation affirming that federally chartered banks and thrifts (collectively national banks) may now provide cryptocustodial services for crypto assets.
FINRA publishes letters or summaries of its letters in response to requests for exemption. We do this to assist industry professionals in understanding the rationale for our decisions. Please note that the decisions apply to the specific situations described.
Under OCC Interpretive Letter 1174, national banks may act as nodes on an independent node verification network (i.e., distributed ledger) to verify customer payments, and may engage in certain stablecoin activities to facilitate payment transactions on a distributed ledger.
In its Interpretive Letter #1170 issued on July 22, 2020, the Office of the Comptroller of the Currency (OCC) issued a legal interpretation affirming that federally chartered banks and thrifts (collectively national banks) may now provide cryptocustodial services for crypto assets.
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Interpretive letters provide guidance on the staffs views as to the application of particular FINRA rules under specific circumstances.
On September 21, 2020, the OCC issued Interpretive Letter 1172, which recognized that stablecoin issuers may desire to place their cash reserves in a reserve account with a bank to provide assurance that the issuer has sufficient assets backing the stablecoin in certain situations.
Under OCC Interpretive Letter 1174, national banks may act as nodes on an independent node verification network (i.e., distributed ledger) to verify customer payments, and may engage in certain stablecoin activities to facilitate payment transactions on a distributed ledger.

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