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On December 9, the Office of the Comptroller of the Currency (OCC) released Interpretive Letter No. 1188, officially allowing national banks to engage in "risk-free principal transactions" involving crypto assets under specific conditions. Banks can act as risk-neutral intermediaries, simultaneously conducting equal reverse transactions with two customers without holding asset inventories, playing a role similar to that of traditional brokers. This represents a significant easing of regulations regarding banks' participation in the crypto market in the United States.
The letter includes three core requirements: first, to implement zero-position hedging, banks must immediately match reverse orders after completing unilateral transactions, ensuring that they always hold no crypto assets on their books to avoid price volatility risks; second, to clarify the business nature, such matching services fall under the "incidental powers" permitted by the National Bank Act, and banks do not need to apply for additional special licenses; third, to emphasize compliance baseline, banks must establish a complete anti-money laundering (AML), cybersecurity, and third-party risk control system before conducting business, and must fulfill reporting procedures to the OCC.
This policy has opened a pathway for traditional financial institutions like JPMorgan Chase and Bank of America to provide crypto services, allowing them to offer Bitcoin and Ethereum spot matching services in a low-risk manner. Following the policy implementation, the market reacted positively, with the price of Bitcoin (BTC) quickly surpassing $93,000, and Ethereum (ETH) simultaneously climbing to the $3,200 level.