The Bank Policy Institute (BPI), which represents 40 of the largest US lenders, including JP Morgan, Goldman Sachs, and Citigroup, is weighing legal action against the Office of the Comptroller of the Currency (OCC) over its approach to issuing national trust bank charters to crypto, payments, and fintech firms.
The OCC has made it easier for non-bank financial firms to obtain national trust charters, granting them the right to operate across all 50 US states. The BPI and other banking groups argue that this exposes the financial system to firms that do not face the same supervisory requirements as fully regulated banks.
Licensing concerns and regulatory opposition
In October 2025, the BPI urged the OCC to reject charter applications from crypto firms Circle and Ripple, as well as UK-based payments firm Wise, warning that allowing firms to access a lighter regulatory framework while offering bank-like products could blur the statutory definition of a bank, heighten systemic risk, and undermine the credibility of the national banking charter itself.
Opposition has extended beyond the major banking lobby. The Conference of State Bank Supervisors wrote to the OCC last month, arguing that granting regulatory approval to firms operating outside core federal banking laws would undermine competition, consumer protection, and financial stability. The Independent Community Bankers of America, representing around 5,000 smaller lenders, warned that the existing proposals would create a significant loophole in a foundational principle of bank regulation and raise critical public policy concerns.
The potential lawsuit would be unusual but not without precedent. The BPI sued the Federal Reserve in late 2024 over changes to bank stress tests, a dispute that resulted in the Fed agreeing to revise its rules, with final proposals due later in March 2026.
The BPI has not confirmed whether it will pursue legal action. Additionally, the OCC did not respond to requests for comment. The reforms are broadly viewed as consistent with the Trump administration's position on integrating crypto and non-traditional financial firms into the mainstream regulatory framework.
