The Bank Policy Institute, a banking industry group representing major US banks, is considering suing the Office of the Comptroller of the Currency over its decision to grant national trust bank charters to crypto and fintech companies. The potential legal challenge was reported on March 9, 2026.

The OCC conditionally approved five crypto firms simultaneously on December 12, 2025, including Circle (which filed under the name First National Digital Currency Bank), Ripple, BitGo, Fidelity Digital Assets, and Paxos. Since then, Bridge (a stablecoin subsidiary of Stripe), Crypto.com, and Protego have also received conditional approvals. In total, 11 companies have filed for or received conditional OCC approval in just 83 days, with 18 digital asset trust bank applications now pending at the agency. Anchorage Digital Bank remains the only crypto-native firm with a fully operational charter; all others are still in conditional status.

A national trust bank charter, issued under the National Bank Act, is not the same as a full commercial bank license. Trust banks cannot accept consumer deposits or make loans as a primary function; they hold and manage assets on behalf of clients. The Guiding and Establishing National Innovation for US Stablecoins Act (GENIUS Act), signed into law July 18, 2025, explicitly authorized these charters as a federal pathway for stablecoin issuers. The OCC is also amending a key regulation, 12 CFR 5.20, effective April 1, 2026, to allow national trust banks to conduct large-scale non-fiduciary digital asset custody, which is a core activity for most applicants.

The BPI's board includes JPMorgan CEO Jamie Dimon, Goldman Sachs CEO David Solomon, and Bank of America CEO Brian Moynihan, all of whom lead institutions facing direct competitive pressure from chartered crypto firms. The BPI specifically opposes charters for Ripple, Circle, Paxos, and payments company Wise, arguing these firms are conducting stablecoin reserve management, payments, and deposit-like functions without meeting full-service bank standards. Paige Pidano Paridon, the BPI's Executive Vice President and Co-Head of Regulatory Affairs, put it plainly: "Companies should not receive trust charters unless they plan to operate as genuine trust companies. If they want to engage in traditional banking activities, they should seek full-service banking charters."

The Conference of State Bank Supervisors has also raised concerns. Its president, Brandon Milhorn, criticized the opacity of the OCC's approval process and left open the possibility of state-level litigation: "With respect to the OCC's actions, litigation is certainly a possibility." The American Bankers Association and Independent Community Bankers of America have voiced similar objections. ABA president Rob Nichols warned that expanded trust charters "blur the lines of what it means to be a bank and create opportunities for regulatory arbitrage," and Rebeca Romero Rainey, President and CEO of the Independent Community Bankers of America, has separately raised concerns about the competitive implications of the OCC's chartering approach.

This is not the first time the OCC's fintech chartering authority has been challenged in court. A similar effort in 2018 and 2019 was blocked by the New York Department of Financial Services, a state regulator. The current BPI effort would mark the first major bank-led legal challenge to OCC fintech chartering authority. Legal experts at Columbia Business School and Georgia State University, as reported by Bloomberg Law, note that the current attempt has stronger legal footing because the GENIUS Act provides direct statutory authority, and any successful lawsuit would likely constrain specific trading activities rather than block stablecoin operations outright.

Regional Impact: South Asia and Africa

The dispute carries direct relevance for users in South Asia and Sub-Saharan Africa, where several OCC applicants operate critical payment and remittance infrastructure. Circle, Ripple, and Wise all serve corridors that depend heavily on low-cost transfers. USDC-based transfers currently run under 1% per transaction, compared to a global average of 6.49% on traditional remittance rails.

India ranks first globally for crypto adoption, Pakistan third, and Bangladesh fourteenth, according to TRM Labs. In Sub-Saharan Africa, stablecoin transactions totaled approximately $54 billion in 2024, accounting for nearly half of all crypto activity in the region. Ripple's RLUSD stablecoin, with a market cap of roughly $700 million (0.24% of the global stablecoin market), has already expanded across Africa through partnerships with VALR, South Africa's largest crypto exchange, pan-African platform Yellow Card, and cross-border remittance service Chipper Cash.

The broader stablecoin market puts these stakes in context. The global market stood at roughly $297 billion in early 2026, with Tether (USDT) and USD Coin (USDC) controlling about 93% of the stablecoin market by capitalization. Stablecoin transaction volume exceeded $4 trillion between January and July 2025, an 83% year-on-year increase.

A prolonged legal challenge could introduce operational uncertainty for licensed issuers serving these payment corridors. Compliance frameworks at local partners in Nigeria and other African markets are partly structured around the regulatory standing of US-domiciled issuers. The GENIUS Act's 1:1 reserve requirement and monthly disclosure obligations are already being referenced as a model framework by regulators in both regions; a protracted US court battle over the charter regime could slow that process.

What Comes Next

The April 1 effective date for the OCC's amended custody rule is a key pressure point in the regulatory timeline and may draw early scrutiny in any legal challenge. Morgan Stanley, Payoneer, and Zerohash (which filed on March 4, 2026) still have applications pending. Developers and businesses building on stablecoin rails in emerging markets should note that OCC conditional approvals mean full operational status for most applicants remains months away, a distinction that matters for near-term planning. Current services face no immediate disruption. The two dates worth monitoring closely are the April 1 rule change and any formal court filing by the BPI or the Conference of State Bank Supervisors.