Protocols & Policy · Bank charters
The spend-management company has applied to the OCC for a national trust bank. Community bankers want a judge to throw out the rule behind those charters.
Ramp, the corporate-card and spend-management company, has applied for a federal charter that would let it hold digital assets for customers, at the same moment community bankers are asking a federal judge to shut that route. The case could decide whether fintech and crypto firms can get a national charter for custody without becoming deposit-taking banks.
Ramp filed its application with the Office of the Comptroller of the Currency on Oct. 16 and announced it on Oct. 19, according to The Crypto Times, which reported that the proposed Ramp National Trust Bank would offer fiduciary investment management, meaning managing investments in clients' best interests, and digital asset custody, and would not accept customer deposits or make commercial loans [2]. An application is not an approval.
A national trust bank is chartered by the OCC but limited to trust operations and related activities, and it does not take deposits [1][3]. ICBA's complaint argues this is the problem: customers of national trust banks "will lack many of the protections that apply to traditional banks, including deposit insurance" [1]. The OCC's March rule says it clarifies the authority of national banks limited to trust operations "to engage in non-fiduciary activities in addition to their fiduciary activities" [3].
The Independent Community Bankers of America sued the OCC and Comptroller Jonathan V. Gould on Oct. 2. It says the March rule and a 2021 interpretive letter "assert[] sweeping new powers to charter national trust banks that are not authorized by the National Bank Act" [1]. By ICBA's count, the OCC "has approved or conditionally approved national trust bank charters for 21 trust banks, at least 13 of which are crypto companies," naming one, Protego Holdings [1].
ICBA asks the court to vacate, or throw out, the rule and the letter, to vacate Protego's approval, and to bar the OCC from using the rule "to grant or conditionally approve any charter" [1]. That last request is where Ramp's application meets the suit. There is no ruling yet.
The dates below come from the rule's Federal Register record, the complaint and The Crypto Times' report [1][2][3].
| Date | Event |
|---|---|
| Jan. 11, 2021 | OCC Interpretive Letter 1176, challenged in the suit [1] |
| Mar. 2, 2026 | OCC final rule "National Bank Chartering" published [3] |
| Apr. 1, 2026 | Rule takes effect [3] |
| Oct. 2, 2026 | ICBA files suit in federal court in Washington [1] |
| Oct. 16, 2026 | Ramp files its application, as reported [2] |
ICBA argues that trust charters let crypto firms "compete directly with community banks by offering similar services without complying with the costly regulatory requirements that ICBA's members face" [1]. It also says the OCC "has not managed an uninsured bank receivership in nearly one hundred years" [1]. The OCC's position, set out in the rule, is that it clarifies authority national trust banks already have [3]. Ramp's announcement, as The Crypto Times reported it, does not address the suit [2].
Watch whether the OCC answers or moves to dismiss, and whether the agency keeps acting on pending trust applications while the case runs.
Holding the Corner.
Not financial advice.