The Independent Community Bankers of America (ICBA), a trade association representing community banks, sued the Office of the Comptroller of the Currency (OCC) on October 2, 2026, over a rule concerning national trust bank charters. ICBA argues that the OCC exceeded its authority by allowing crypto firms to conduct substantial non-fiduciary activities under those charters. The suit challenges the OCC’s March 2, 2026, final rule related to Interpretive Letter 1176; the available information does not establish that a court has ruled on the case.
What the lawsuit challenges
ICBA filed an Administrative Procedure Act lawsuit in the U.S. District Court for the District of Columbia against the OCC. Its challenge targets the agency’s March 2, 2026, final rule related to Interpretive Letter 1176. The dispute is about the scope of activities a national trust bank may conduct and the safeguards that should apply—not a finding that any particular company has violated the law.
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ICBA President and CEO Rebeca Romero Rainey said, “The OCC’s decision to allow companies to obtain national trust bank charters to conduct substantial non-fiduciary activities exceeds the authority Congress granted the agency.” That is the trade group’s legal position, not a court’s conclusion.
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Why ICBA objects to crypto trust charters
ICBA says a national trust charter can give a company the credibility of a federal bank charter while avoiding safeguards it associates with insured depository institutions. It points to deposit insurance, capital and liquidity requirements, consolidated supervision, and Community Reinvestment Act obligations as differences that matter to its challenge.
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Those assertions describe ICBA’s argument. A national trust bank should not automatically be treated as an ordinary retail bank: the relevant activities, deposit-taking, insurance status, and regulatory obligations depend on the charter and the institution. The cited materials do not provide a complete side-by-side account of every trust-bank and retail-bank requirement.
What the OCC approved—and when
The OCC announced a set of conditional decisions on December 12, 2025. They included new national trust bank charter approvals for First National Digital Currency Bank and Ripple National Trust Bank, plus conditional conversion approvals for BitGo Bank & Trust, Fidelity Digital Assets, and Paxos. The OCC said it reviewed each application on its individual merits and made the decisions subject to conditions.
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| Company or group | OCC action described in the cited materials | Date and qualification |
|---|---|---|
| First National Digital Currency Bank | Conditional approval for a new national trust bank charter | December 12, 2025 |
| Ripple National Trust Bank | Conditional approval for a new national trust bank charter | December 12, 2025 |
| BitGo Bank & Trust, Fidelity Digital Assets, and Paxos | Conditional approvals to convert to national trust banks | December 12, 2025 |
| Coinbase National Trust Company | Listed in the OCC decisions index as Corporate Decision 1370 | April 2, 2026; a separate decision entry, not part of the December 2025 batch |
These distinctions matter: the December decisions included both new-charter and conversion approvals, while Coinbase appears in a separate later index entry. The cited materials do not establish that Coinbase received the same decision as Ripple or on the same date. Nor does a conditional approval, by itself, mean that all proposed activities are already operating without further conditions.
What Ripple proposed to do under its trust charter
The OCC’s published Ripple decision describes proposed activities that help explain the disagreement over what a trust company can do. They include managing a segregated liquid-asset reserve backing RLUSD, providing collateral trustee services for RLUSD holders, and offering crypto custody to institutional customers. The letter sets out the OCC’s view that trust-company operations may include fiduciary services as well as certain non-fiduciary custody and safekeeping activities.
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The OCC presents its approvals as conditional, application-specific decisions made under applicable statutory and regulatory factors. Comptroller Jonathan V. Gould said in the agency’s December 12, 2025, announcement: “New entrants into the federal banking sector are good for consumers, the banking industry and the economy.” That agency position contrasts with ICBA’s view that the challenged rule stretches the OCC’s statutory authority.
How many trust banks are involved?
A Gizmodo report published October 6, 2026, said the complaint counts 21 trust banks approved or conditionally approved under the Trump administration, at least 13 of which it describes as crypto companies. Those figures are attributed to the complaint as reported by Gizmodo; they are not an independently verified OCC aggregate in the cited materials.
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The OCC’s Ripple decision letter separately reports that, as of September 30, 2025, OCC-supervised uninsured national trust banks had $6.8 trillion in assets under administration: $1.6 trillion in custody and safekeeping accounts and $5.2 trillion in fiduciary accounts. Those totals cover the category described by the OCC, not crypto trust banks alone.
For context, the OCC’s December 12, 2025, announcement said the federal banking system included more than 1,000 national banks, federal savings associations, and federal branches of foreign banking organizations. The agency said these institutions conducted approximately 67 percent of U.S. banking activity, held more than $17 trillion in combined assets, and administered more than $85 trillion in assets under control. These are OCC figures for the federal banking system, not measures of the crypto trust-bank segment.
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What happens next
The lawsuit puts the OCC’s authority to issue the challenged rule before a federal court. The practical question is how the court will interpret that authority and the rules governing national trust bank activities. The available material establishes that ICBA filed the challenge, but does not establish a judicial ruling or the case’s later procedural developments.
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