Interpretations and Actions: November 2025

Vol. 38, No. 11

Interpretive Letter

Letter No.	Topic
1186	Letter confirms that, based on the facts and circumstances of the bank's proposal, national banks may, as an activity incidental to the business of banking, pay network fees on blockchain networks to facilitate otherwise permissible activities and hold, as principal, amounts of crypto-assets on balance sheet necessary to pay network fees for which the bank anticipates a reasonably foreseeable need and to test otherwise permissible crypto-asset-related platforms.

Letter No.

Topic

Letter confirms that, based on the facts and circumstances of the bank's proposal, national banks may, as an activity incidental to the business of banking, pay network fees on blockchain networks to facilitate otherwise permissible activities and hold, as principal, amounts of crypto-assets on balance sheet necessary to pay network fees for which the bank anticipates a reasonably foreseeable need and to test otherwise permissible crypto-asset-related platforms.