The Bank Policy Institute, a lobbying group whose board includes the CEOs of JPMorgan Chase, Goldman Sachs, and Citigroup, is actively reviewing legal options to challenge the Office of the Comptroller of the Currency over its decision to grant national trust bank charters to crypto and fintech firms. As of March 10, 2026, no lawsuit has been filed, but three separate banking trade groups have publicly opposed the OCC's charter expansion, and BPI has retained outside counsel to evaluate its options.
Eleven Companies, Eighty-Three Days
The numbers tell the story. Between December 12, 2025 and March 4, 2026, eleven companies either received conditional approval or filed applications for OCC national trust bank charters.
The December batch came first: Ripple, Circle, BitGo, Fidelity Digital Assets, and Paxos all received conditional approvals on the same day. By February, Bridge (Stripe's subsidiary), Protego, and Crypto.com had joined them. Morgan Stanley filed on February 18, Payoneer on February 24, and Zerohash on March 4.
Two more applications sit in the queue. Coinbase and World Liberty Financial, the Trump-backed DeFi project, have both filed but remain under review.
For context, Anchorage Digital Bank remains the only crypto-native firm with a fully operational national trust bank charter. Every other approval so far is conditional, meaning the firms must meet additional requirements before they can begin operations.
What a National Trust Bank Charter Actually Does
A national trust bank charter is a federal license from the OCC that lets a company operate as a trust bank under federal law. The core function: holding and custodying assets on behalf of clients. It does not allow consumer deposit-taking or lending as a primary function.
The appeal is straightforward. A single federal charter replaces the patchwork of individual state licenses that crypto firms have spent years collecting. Kraken, for example, recently became the first crypto firm to access the Federal Reserve payment system through a different route, its Wyoming SPDI charter. A national trust charter from the OCC would offer similar federal-level access without going state by state.
Most fintech companies have historically relied on sponsor bank relationships to operate, partnering with licensed banks that handle the regulated parts. Federal regulators began scrutinizing those relationships aggressively in 2023 and 2024, pushing firms toward obtaining their own charters.
The Banking Lobby's Argument
The BPI represents roughly 40 major lenders. Its argument is specific: the OCC is granting federal charters to firms that will face lighter regulatory requirements than traditional banks while offering similar services.
"Allowing firms to deliver bank-like products under lighter regulatory frameworks could blur the legal definition of a bank and increase risks to the financial system," BPI stated in its formal position.
The concern centers on OCC Interpretive Letter 1176, which reinterprets who qualifies as a national trust bank and what activities digital-asset custodians can perform. Traditional banks must meet capital adequacy requirements, submit to stress testing, comply with the Community Reinvestment Act, and maintain deposit insurance through the FDIC. National trust bank charter holders skip most of those requirements because they are not taking consumer deposits.
BPI is not alone. The Conference of State Bank Supervisors and the Independent Community Bankers of America have also raised objections. On March 5, the American Bankers Association rejected a White House compromise proposal on stablecoin regulation, signaling that the industry opposition extends beyond the charter issue into the broader legislative fight.
The Regulatory Calendar Creates Urgency
A new OCC regulatory amendment takes effect on April 1, 2026. That deadline may be forcing BPI's hand. If the banking lobby files a lawsuit under the Administrative Procedure Act before the amendment takes effect, it could argue that the OCC failed to follow proper rulemaking procedures when it expanded charter eligibility through interpretive letters rather than formal rulemaking.
This is the same legal strategy BPI has used before. In late 2024, it joined a lawsuit against the Federal Reserve over its stress-testing framework, arguing that the Fed had used guidance documents to impose requirements that should have gone through notice-and-comment rulemaking.
The timing also intersects with the stalled CLARITY Act, which would establish a federal framework for stablecoin regulation. If Congress passes stablecoin legislation before BPI files suit, the legal landscape shifts. If it does not, BPI's case becomes stronger because the OCC would be chartering firms in a regulatory vacuum.
Who Wins and Who Loses
For crypto firms, a national trust bank charter is the difference between being a regulated financial institution and being a tech company with a bank partnership. BitGo already operates as a qualified custodian under state law, but a federal charter would let it custody assets under a single regulatory framework nationwide. Ripple, which has spent years fighting the SEC, would gain federal legitimacy as a banking entity. Crypto.com would add custody and staking services to its existing card and exchange business.
For traditional banks, the threat is competitive. If crypto firms can offer custody, staking, and stablecoin services under a federal charter without the capital requirements and compliance costs that banks bear, the playing field tilts. JPMorgan, which launched its own blockchain unit (Kinexys, formerly Onyx) and handles billions in tokenized transactions, is competing directly with some of the charter applicants.
For users, the outcome determines how crypto custody and banking services are regulated in the United States. A federal charter means federal oversight, standardized rules, and a single regulator. The alternative is the current system: a mix of state licenses, sponsor bank relationships, and offshore structures that vary by jurisdiction.
What Card Holders Should Watch
The charter fight has direct implications for anyone using a crypto card. Several charter applicants, including Crypto.com and Bridge (which powers stablecoin-linked cards for Stripe), operate card programs. A national trust bank charter would let these firms move funds through the federal banking system directly rather than routing through sponsor banks.
That could mean lower fees for end users. Today, the multi-hop path from crypto wallet to card transaction involves conversion spreads, sponsor bank fees, and network costs. Direct federal banking access could eliminate one or two of those intermediaries. It could also mean stricter compliance requirements, including enhanced KYC, which would affect no-KYC card options currently available.
The KAST $80 million Series A at a $600 million valuation shows where investor capital is flowing: stablecoin payment infrastructure. If charter applicants like Circle and Bridge gain federal banking status, they become the rails that card programs build on.
Overview
The Bank Policy Institute, representing roughly 40 major banks including JPMorgan, Goldman Sachs, and Citigroup, is considering a lawsuit against the OCC over its decision to grant national trust bank charters to crypto and fintech firms. Eleven companies have filed or received conditional approvals in an 83-day window. The legal argument centers on OCC Interpretive Letter 1176, which banking groups say expanded charter eligibility without proper rulemaking. An April 1 regulatory deadline may force BPI to act. The outcome will determine whether crypto firms operate under federal banking oversight or continue relying on state licenses and sponsor bank relationships.
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- Kraken Becomes the First Crypto Firm to Access the Federal Reserve Payment System
- The US Treasury Wants Congress to Let Crypto Exchanges Freeze Your Funds Without a Court Order
