September 20, 2020

Volume X, Number 264

September 18, 2020

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Better Than Under the Mattress - OCC Opens the Door to Cryptocurrency Custody

The Office of the Comptroller of the Currency (OCC) recently published a letter clarifying the authority of national banks and federal savings associations to provide cryptocurrency custody services for customers.  National and state banks and thrifts have long provided safekeeping and custody services, including both physical objects and electronic assets. In the letter, the OCC recognized that providing cryptocurrency custody services, including holding unique cryptographic keys associated with cryptocurrency, is a modern form of traditional bank activities related to custody services. The OCC also noted crypto custody services may extend beyond passively holding "keys." The OCC recognized that, as the financial markets evolve, there will be an increasing need for banks and other service providers to use technology in innovative ways to serve the need of their customers.

© Polsinelli PC, Polsinelli LLP in CaliforniaNational Law Review, Volume X, Number 223


About this Author


Richard Levin brings his experience as a senior legal and compliance officer on Wall Street and in London to bear in advising clients on corporate, securities and regulatory issues. A problem-solver by nature, his practice focuses on helping financial services and technology (FinTech) clients identify and address regulatory issues as they build their businesses.  

The FinTech sector is experiencing rapid changes that are producing innovative new technologies: digital currencies, blockchain technology, peer to peer lending, robo advisors, crowdfunding portals, and...


David Allred believes that excellent client service begins with strong relationships. David is a member of the Banking and Financial Institutions practice and represents both publicly traded and privately held banks at all stages of the business cycle, from formations to a mature business. As an accountant and an attorney, David brings a unique perspective to providing corporate advice to clients in ever-changing regulatory environments. He has served banks on a broad range of complex legal issues including: 

  • Mergers and acquisitions
  • General corporate matters
  • Regulatory compliance
  • Securities
  • Public and private offerings
  • Formations

His distinctive background as a certified public accountant enables him to add another layer of skill for clients. Prior to joining Polsinelli, David practiced law at a Washington, D.C. based law firm for over seven years. Before graduating law school, he worked at a then "big five" accounting firm providing legal consulting services.