Industry Stakeholders Raise Concerns Over Fintech Trust Charter Applications

In October 2025, the Bank Policy Institute (BPI) issued a series of letters opposing efforts by several digital asset and payment firms to secure federal banking charters from the Office of the Comptroller of the Currency (OCC). BPI raised concerns that these companies are seeking trust charters even though, in BPI's view, they will not operate as traditional chartered financial institutions.

BPI argues that the OCC lacks authority to grant the digital asset firms' request for trust charters because the firms plan to engage in traditional banking activities, including managing stablecoin reserves, facilitating payments, and taking deposits. In BPI's view, approving these applications could exceed the OCC's authority under federal law and transform trust charters into a loophole for companies to gain the regulatory and operational benefits of charters, while avoiding the increased compliance burdens of full-service bank charters.