What does the OCC Interpretive Letter mean regarding INVN and Stablecoins means for Payment Companies?

The former Coinbase Chief Legal Officer, who is now Chief Comptroller of the OCC, issued an interpretive letter stating that it was fine for banks to use stablecoins and INVN’s (“blockchains”)


  • Crypto Exchanges like Coinbase. Banks will have to have a treasury function to exchange fiat to crypto. 
  • Tether and other well known Stablecoins – are there any good stablecoins?
  • Core banking providers – US regional banks do not have the scale to be able to produce their own technology and rely on core providers like Jack Henry. These will be able to charge more for new products
  • AML providers – blockchain analytics firms like Chainalysis, aml screening providers like ComplyAdvantage and transaction monitoring providers like Nice Actimize will benefit from the increased risk of blockchain transactions 


  • Traditional payment mechanisms like SWIFT, ACH and Fedwire – rather than using ACH and Fedwire, banks will use the blockchain instead
  • Traditional payment companies that use SWIFT, ACH and Fedwire – companies who can not provide a crypto based service will suffer
  • The US Dollar and Fiat Currency – having every US bank use crypto currencies for undermine traditional fiat currency

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