Who Is Dee Choubey and How OpenReserve Won a National Bank Charter

Dee Choubey is the chief executive and an organizer of OpenReserve Bank, National Association, a proposed full-service national bank in Salt Lake City, Utah. He founded the consumer finance company MoneyLion and led it as chief executive. The Office of the Comptroller of the Currency granted his bank's charter application preliminary conditional approval on 2 September 2026.

Dee Choubey at a Glance

The approval letter carries one number that tells you how seriously the regulator is treating this. OpenReserve Bank has to raise at least $210 million of initial paid-in capital, net of all organizing and preopening expenses, before the OCC will let it open. The application went in on 13 April 2026 and the decision came back 142 days later. And the charter it won is the one the largest names in crypto asked for and settled short of.

What Did the OCC Approve on 2 September 2026?

Corporate Decision #1389 grants preliminary conditional approval to establish OpenReserve Bank, National Association. It will be a full-service insured national bank with its main office in Salt Lake City and no branches. The organizers filed on 13 April 2026 under the National Bank Act, and Proposed Charter No. 27203 is reserved against the application.

The business plan described in the letter is broad. The bank intends to offer deposit and lending products with tokenized capabilities across every deposit product. Payments and treasury services, digital asset services, foreign correspondent banking and a banking-as-a-service platform are all in there too. It also plans to hold small amounts of digital assets on its own balance sheet to pay network gas fees. The OCC confirmed that specific activity as permissible in an interpretive letter dated 18 November 2025.

The stablecoin arm is a plan, not a permission

This is the detail most coverage flattens, and you should hold onto it. The decision says the bank "plans to form a wholly-owned stablecoin subsidiary" for issuance, custody, conversion and payment of dollar-denominated reserve-backed stablecoins. The very next sentence in the letter reads "An application for the subsidiary has not yet been filed." A stablecoin business is described in that document. It is not authorised by it. Our explainer on how stablecoins hold their peg covers the model such a subsidiary would have to run.

The OCC attached four conditions. The first requires the bank to conform its activities, stablecoin issuance included, to the GENIUS Act and any future implementing rules, with compliance judged at the OCC's sole discretion. The others demand sixty days written notice and a written no-objection before any significant change to the business plan. They also set a tier 1 leverage floor of 12.0 percent through the first three years of operation. And no senior executive or director can be appointed without a no-objection letter first.

What Is the Difference Between a Trust Charter and a Full Service Charter?

Think of it as the difference between holding the keys to somebody else's safe and owning the safe yourself. A trust charter is the first one. You can look after what's inside, move it, account for it and charge a fee for the service. A full-service charter is the second. You open your own safe, invite the public to put money into it, and lend that money back out to someone else.

That second thing is the prize, and it is why the distinction matters more than the shared word "charter" suggests. A national trust bank acts in a fiduciary capacity. It does not take insured deposits from the public and it does not run a lending book against them. A full-service national bank does both. That's why the OCC letter rests its approval on the understanding that OpenReserve will apply for FDIC deposit insurance and for stock in a Federal Reserve Bank. Trust applicants generally need neither.

You can see how unusual the full-service ask is on the OCC's own books. Its pending digital-asset licensing applications table carries thirteen filings dated between 27 January and 19 August 2026. Ten of the thirteen are national trust entities by name. The trust route is the default for anyone touching crypto, and it has been for years.

Who Is Dee Choubey and What Did He Build Before OpenReserve?

His legal first name is Diwakar. He signs filings that way and the OCC letter lists him that way. A search on "Dee Choubey" and a search on "Diwakar Choubey" return different halves of one career.

The bigger half is MoneyLion, the consumer finance app he founded in 2013. MoneyLion reached the public markets through a special purpose acquisition company, Fusion Acquisition Corp., which changed its name to MoneyLion Inc. on 28 September 2021 (SEC CIK 1807846). The company then filed a Form 15-12G on 28 April 2025, which is the paperwork a company files to deregister its securities and stop being publicly traded. Before MoneyLion he worked at Goldman Sachs, Citadel and Barclays Capital, and he holds a BA in Economics with Honors from the University of Chicago. Those three employers and the degree come from secondary reporting rather than a filing, so you should weight them accordingly.

One framing deserves dropping straight away, and it is the two-man-startup version. The OCC's no-objection list names eleven people, six of them organizers. Richard Correia is President and Chief Operating Officer. The list also clears a chief architect, a chief technology officer, a chief risk officer and a chief financial officer. Choubey and Correia are the names that travel, and Correia came from Merrill Lynch and Citadel, but the group the regulator cleared runs deeper than the two of them.

Why Did OpenReserve Clear What Circle, Ripple, Paxos and BitGo Did Not?

Every one of those four went to the OCC for a national trust charter. None asked for the full-service version. So the fair framing is not that OpenReserve beat them at the same game. It asked a different and larger question, and the regulator said yes at the preliminary stage.

Part of the answer is money and part of it is structure. Choubey's group turned up with a capital plan the OCC was prepared to size at $210 million. The 12.0 percent leverage floor attached to it runs well above what a bank that size would ordinarily carry. Applicants who only want to hold customer assets do not have to bring that. The four trust applicants were also asking in a different regulatory season, before the GENIUS Act gave the agency a statute to condition an approval against.

The funding lines up with the same date. OpenReserve Holdings Inc. filed a Form D with the SEC on 11 June 2026 (CIK 2135225). It reports a $25,000,000 offering with $24,005,501 sold to eleven investors, split between $15,005,501.94 of Series Seed Preferred Stock and $9,000,000 of SAFEs. Its stated date of first sale is 13 April 2026, the same day the charter application reached the OCC. a16z crypto led the round, with participation from several crypto-native venture arms. The filing itself names no investors, so treat the lead as reported rather than filed.

The "five month old applicant" line needs one correction

The venture is young. The legal entity is not quite as young as the headline suggests. OpenReserve Holdings Inc. is a Delaware corporation whose year of incorporation is given as 2025, and EDGAR records its previous name as FlatironX Technologies Inc. What happened in April 2026 was a funded, renamed company filing a charter application. It was not a company springing into existence. The speed here belongs to the OCC's 142-day turnaround, which is the genuinely remarkable part of the story.

What Could Still Stop OpenReserve Bank From Opening?

Think of it as planning permission rather than a finished building. The OCC says as much in the letter, in language reserving its right to modify, suspend or rescind the approval if any interim development warrants it.

Two stopwatches started on 2 September 2026. If the capital is not raised within twelve months, or the bank is not open for business within eighteen months, the approval expires. The letter adds that the agency "is opposed to granting extensions, except under the most extenuating circumstances." If you are tracking this story, treat those two dates as real rather than decorative.

Three more gates sit outside the bank's control. FDIC insurance is a separate application to a separate agency, and the OCC letter only records the expectation that OpenReserve will pursue it. Federal Reserve Bank stock is the same story. And twelve preopening requirements have to be satisfied before the bank can even request its preopening examination. They cover an external audit engagement, an independent security review of the electronic banking platform, and a written no-objection on the final systems architecture.

What all this means for you as a trader is narrower than the headlines imply. No deposit has been taken, no loan has been written and no token has been issued. If a bank-issued dollar stablecoin eventually arrives from this charter, it lands in a contested market. The bank lobby has already fought hard over who is allowed to pay yield on stablecoins. A listed issuer has already seen its shares repriced on that same argument, as we covered in the Circle stablecoin yield-ban selloff. Bank-adjacent dollar tokens like the Open USD launch are the shape of the competition OpenReserve would enter. And the deposit-and-lend model it proposes is a regulated cousin of onchain crypto lending.

Frequently Asked Questions

Is OpenReserve Bank open for business?

No. It holds preliminary conditional approval only, and the OCC letter is explicit that final approval and authorisation to open will not be granted until every preopening requirement is met. The entity has to carry the words "In Organization" after its name in official documents until it opens.

What does preliminary conditional approval from the OCC mean?

It means the OCC reviewed the application and found the proposal meets its regulatory and policy requirements. The organizers may form the corporate entity and start building the bank. That is a permission to organize rather than a permission to bank. The Comptroller's Licensing Manual charters booklet sets out every step between the two.

Can OpenReserve Bank issue a stablecoin?

Not yet. The decision describes a planned wholly owned stablecoin subsidiary and then states that no application for it has been filed. Any issuance would also have to conform to the GENIUS Act on terms the OCC decides at its own discretion.

Does a national bank charter automatically mean FDIC-insured deposits?

No, and this trips people up constantly. Deposit insurance is granted by the FDIC through its own application, and the OCC's approval here rests on the understanding that OpenReserve will apply for it. A charter and an insurance certificate are two different documents from two different agencies.

Bottom Line

Two dates belong in your calendar, both derived from the 2 September 2026 decision date. The capital clock runs out on 2 September 2027 and the opening clock on 2 March 2028, and missing either one voids the approval. Three checkpoints in between carry real information. Those are the FDIC insurance decision, the stablecoin subsidiary application that has not been filed, and any disclosure of how close the $210 million stands. Until that subsidiary application appears on the OCC's docket, this is a bank charter with a crypto business plan attached. It is not a crypto business with a bank charter, and the two trade very differently.

This article is for informational purposes only and does not constitute financial or investment advice. Cryptocurrency trading involves substantial risk. Always conduct your own research before making trading decisions.