Major Banks Consider Lawsuit Against OCC Over Crypto Trust Charters

The Bank Policy Institute, a trade group whose board includes the CEOs of JPMorgan Chase, Goldman Sachs, and Citigroup, has retained outside counsel and 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 cryptocurrency and fintech firms. As of March 10, 2026, no lawsuit has been filed, but the pressure is building fast.

The dispute centers on a wave of regulatory approvals that accelerated sharply in recent months. Between December 12, 2025 and March 4, 2026, eleven companies either received conditional approval or submitted applications for OCC national trust bank charters, according to SpendNode. In December alone, the OCC issued conditional approvals to BitGo, Fidelity Digital Assets, Ripple, and Paxos. February brought conditional licenses to Crypto.com, Bridge, and Stripe. Blockchain infrastructure firm ZeroHash submitted its application on February 27. Trump-backed World Liberty Financial applied in January to expand use of its USD1 stablecoin and is still awaiting a decision.

The BPI, which represents roughly 40 major U.S. lenders including Goldman Sachs, JPMorgan, American Express, and Citigroup, argues that the OCC's approach blurs the legal definition of a bank. The group's earlier submissions urged the OCC to deny charter requests from Circle, Ripple, and payments firm Wise, with the BPI contending that granting such charters allows firms to offer bank-like services nationwide under a lighter regulatory framework than applies to full-service national banks. In its filings, the BPI argued the policy could endanger Americans and the financial system.

The specific legal flashpoint is OCC Interpretive Letter 1176, which the BPI says expanded charter eligibility without proper rulemaking, bypassing the formal notice-and-comment process that typically governs major regulatory changes. Three separate banking trade groups have now publicly opposed the OCC's charter expansion, and opposition has also come from state regulators and community banks.

An April 1 regulatory deadline may force the BPI to make a final call on whether to file suit, according to SpendNode, though the nature of that deadline is not detailed in public reporting. The Guardian reported that the BPI has not yet made a final decision on whether to proceed with litigation.

For context on where the industry actually stands: Anchorage Digital Bank remains the only crypto-native firm to have moved from conditional approval to a fully operational national trust bank with a final charter, according to Tradingview. The rest of the named firms are still operating under conditional status, which means the legal battle, if it comes, would arrive while the regulatory framework is still taking shape. The outcome, as SpendNode framed it, will determine whether crypto firms operate under federal banking oversight or continue relying on state licenses and sponsor bank relationships.