Joint Trades Letter to the OCC regarding Pending Applications by Nonbanks for a Trust Charter

Dear Directors:

The undersigned associations (the "Associations") appreciate the opportunity to comment on recent national bank charter applications, including national trust charter applications submitted by National Digital TR CO; Fidelity Digital Assets, NA; First National Digital Currency Bank, N.A.; and Ripple National TR Bank (each, an “Applicant” and collectively, the “Applicants”) to the Office of the Comptroller of the Currency (“OCC”) since April 2025 (each, an "Application" and collectively, the "Applications").

Based on the Associations' review of the limited information included in the public portions of the Applications, the Associations believe that there are significant policy and legal questions as to whether the Applicants’ proposed business plans involve the types of fiduciary activities performed by national trust banks. The suitability of the trust charter for the Applicants is a material question of public policy. Granting these Applications could represent a fundamental departure from existing OCC precedent, and the Associations firmly believe that such a departure demands public input.

As discussed further herein, the Associations believe that:

1. The public portions of the Applications do not allow for meaningful public scrutiny; and 
2. Broader change to OCC policy with respect to trust activities requires public scrutiny.

Download the joint comment letter to read the full text.