Bitcoin Policy Institute · fixbasel.org (interactive version)
Tell the Fed, OCC, and FDIC: Bitcoin deserves risk-based capital treatment, not a blanket penalty that keeps American banks out of Bitcoin.
Public comment deadline: June 18, 2026 (23:59:59 ET)
1,250% — the risk weight Basel assigned to bitcoin. It is the harshest penalty in the entire banking framework.
The Federal Reserve, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation are currently accepting public comments on proposed changes to U.S. bank capital rules.
This is a critical opportunity for Bitcoin users, bank customers, entrepreneurs, investors, and concerned citizens to explain why Basel's proposed treatment of Bitcoin is wrong.
Under the Basel cryptoasset framework, Bitcoin receives a harsh 1,250% risk weight. In practice, that means a bank may be required to hold capital equal to the full value of its Bitcoin exposure before additional buffers. That treatment does not make Bitcoin services safer. It makes them economically impractical for regulated banks to offer.
America cannot lead the next generation of financial infrastructure if American banks are effectively blocked from touching the world's largest decentralized digital asset.
The Basel standards are a non-binding international set of guidelines that recommend how banks should operate. Regulators often rely on these rules to help determine how banks can safely operate and what products and services banks can offer their customers.
Basel includes recommendations for "risk-weight" of assets. This is a rating that determines how inherently risky an asset is. When an asset receives a very high risk weight, banks must take greater precautions by holding significantly more capital against it. That raises costs and can make the activity commercially impossible.
In 2022, Basel published standards on how banks should risk-weight cryptoassets generally. They assigned all cryptoassets, including Bitcoin, the harshest rating possible: a 1,250% risk weighting. This rating is harsher than any other asset and more severe than what is assigned to a broad range of opaque and illiquid credit instruments.
| Asset | Risk weight |
|---|---|
| U.S. Dollar (Cash) | 0% |
| Gold | 0% |
| U.S. Treasuries | 0% |
| Corporate Debt (A-rated) | 50% |
| Corporate (Unrated) | 100% |
| Speculative Equity | 400% |
| Bitcoin | 1,250% |
For every dollar of Bitcoin on a bank's balance sheet, banks must fully offset that Bitcoin with another dollar in reserve. This treatment makes providing Bitcoin products and services extremely expensive for banks compared to all other asset classes.
A 1,250% risk weight does not merely affect a bank's internal balance sheet. It determines what services regulated banks can realistically provide.
If Bitcoin activity is made uneconomic for U.S. banks, banks will be deterred from offering custody, settlement, secured lending, treasury services, payment infrastructure, market-making support, hedging tools, and risk-management services for Bitcoin users and businesses.
This pushes Bitcoin activity away from regulated banks and toward less supervised venues, offshore institutions, or fragmented workarounds. That is worse for customers, worse for supervisors, and worse for American leadership.
There are plenty of risky instruments in crypto — but Bitcoin is fundamentally different.
Bitcoin has no issuer. It has no borrower. It has no management team. It has no coupon, redemption promise, reserve portfolio, or defaulting counterparty. Bitcoin is an issuerless, decentralized, globally traded capital asset with a transparent supply schedule, public settlement history, open-source validation, and continuous market pricing.
Its risks are real, but they are not mysterious. They are primarily operational risks that can be measured, supervised, and capitalized directly.
The agencies should reject Basel's blanket 1,250% treatment for Bitcoin. Instead, they should develop a risk-sensitive framework that:
You do not need to be a lawyer, banker, or policy expert. Regulators accept comments from the public because these rules affect the public.
Use this as a starting point — please rewrite it in your own words.
Subject: Comment on Bank Capital Treatment of Bitcoin
To the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation:
I am submitting this comment because I believe U.S. bank capital rules should treat Bitcoin according to its actual risks, not through a blanket penalty that makes regulated bank involvement economically impractical.
Bitcoin is not risk-free. It has price volatility, custody risk, cybersecurity risk, liquidity risk, and operational risk. Banks that engage with Bitcoin should be required to manage those risks through strong controls, audited custody standards, prudent inventory limits, appropriate supervision, and robust operational safeguards.
But Bitcoin is fundamentally different from many other cryptoassets. It has no issuer, borrower, management team, coupon, redemption promise, reserve portfolio, or defaulting counterparty. It is not a claim on a company, stablecoin issuer, DeFi protocol, or lending platform.
Bitcoin is an issuerless, decentralized, globally traded capital asset with a transparent supply schedule, public settlement history, open-source validation, and continuous market pricing. Its risks are real, but they are not opaque. They are primarily market, custody, cybersecurity, operational, liquidity, hedging, and concentration risks. Those risks can be measured, supervised, and capitalized directly.
The blanket 1,250% risk weight proposed by Basel is therefore the wrong tool for Bitcoin's actual risk profile. Regulation that lumps Bitcoin together with speculative instruments and opaque credit products fails to distinguish among different assets, different structures, and different risks.
At an 8% minimum capital ratio, a 1,250% risk weight can require capital equal to the full value of a bank's Bitcoin exposure before additional buffers. That treatment does not make banks safer. It prevents regulated banks from offering custody, settlement, secured lending, treasury services, payment infrastructure, market-making support, hedging tools, and client services that Bitcoin users and businesses increasingly need.
I respectfully urge the agencies not to adopt or entrench Basel's blanket 1,250% treatment for Bitcoin. Instead, the agencies should adopt their own risk-sensitive framework that addresses Bitcoin's actual risks through market-risk capital, operational-risk treatment for custody and key management, cybersecurity standards, recognition of hedging, audited custody controls, prudent inventory limits, and graduated concentration limits.
The agencies should also distinguish Bitcoin from issuer-backed tokens, stablecoins, DeFi instruments, and other cryptoassets with materially different risk profiles. Bitcoin should not receive special treatment. It should receive accurate treatment.
A risk-sensitive framework would better protect safety and soundness while allowing Bitcoin-related activity to occur inside regulated, supervised U.S. financial institutions. A blanket penalty would push activity away from regulated banks, reduce consumer choice, and weaken American leadership in Bitcoin and financial technology.
America cannot lead the next generation of financial infrastructure if American banks are effectively blocked from participating in Bitcoin.
Submit a comment before June 18, 2026.
Be respectful. Be specific. Use your own words.
The comment period
The Federal Reserve, OCC, and FDIC are accepting public comments on proposed changes to U.S. capital rules. Comments are due June 18, 2026.
Your comment does not need to be long. It should be respectful, specific, and personal. Do not include private financial information, account details, wallet addresses, seed phrases, or anything confidential.