The Bank Policy Institute (BPI), representing 40 of the largest US lenders, including JP Morgan, Goldman Sachs, and Citigroup, is considering legal action against the Office of the Comptroller of the Currency (OCC) over its decision to issue national trust bank charters to crypto, payments, and fintech firms.
By easing the process for non-bank financial firms to obtain these charters, the OCC is enabling them to operate across all 50 US states. However, the BPI and other banking groups are concerned that such firms might not be subject to the same supervisory requirements as fully regulated banks.
Regulatory Fears and Cautionary Stances
In October 2025, the BPI advised the OCC to deny charter applications from crypto firms Circle and Ripple, along with UK-based payments firm Wise. The BPI highlighted that these firms might operate under a less stringent regulatory framework while providing bank-like services, potentially blurring legal definitions of banking activities, increasing systemic risks, and compromising the integrity of the national banking charter.
This opposition extends beyond the major banking lobby. The Conference of State Bank Supervisors wrote to the OCC last month, arguing that granting regulatory approval outside core federal banking laws would harm competition, consumer protection, and financial stability. Similarly, the Independent Community Bankers of America, representing approximately 5,000 smaller lenders, warned that these proposals could undermine a fundamental principle in bank regulation and raise significant public policy issues.
Such legal action against the OCC would be rare but not unprecedented. In late 2024, the BPI filed a lawsuit against the Federal Reserve over changes to bank stress tests, leading to revised rules with final proposals expected later in March 2026.
The BPI has yet to confirm if it will proceed with legal action. The OCC did not respond to requests for comment on the matter. Despite this, these reforms align broadly with the Trump administration’s stance on integrating crypto and non-traditional financial institutions into mainstream regulatory frameworks.
