BPI and ICBA Request for Extension on OCC’s Notice of Proposed Rulemaking on National Bank Chartering

To Whom It May Concern,

The Bank Policy Institute^[1] and the Independent Community Bankers of America^[2] respectfully request a 30-day extension of the comment period for the Office of the Comptroller of the Currency's Notice of Proposed Rulemaking on National Bank Chartering.^[3]

The proposed rule would amend regulations implementing the OCC's chartering authority under the National Bank Act - specifically with regard to national trust banks. In describing the powers of a national trust bank, the proposed rule would replace the term "fiduciary activities" with the term "the operations of a trust company and activities related thereto." The OCC asserts that this proposed change is merely a clarification designed to "eliminate potential confusion as to the intent, and OCC's interpretation, of the existing regulation." However, any changes concerning the OCC's chartering authority or the powers of national trust banks deserve careful scrutiny.

The proposed change would be especially significant due to the unprecedented influx of national trust bank charter applications over the past year, as well as the OCC's recent conditional approval of some of those applications. Unlike national trust banks, which engage in traditional trust banking activities with their customers, many of these new applicants have novel business models related to cryptocurrencies (including stablecoins) or payments activities. These novel businesses have the potential to change the landscape of banking with important implications for safety and soundness and systemic risk.

For these reasons, we do not believe that the proposed rule's 30-day comment period is sufficient to fully consider the potential scope of the proposal's implications for the banking system. Therefore, we respectfully ask for an additional 30 days to solicit feedback from our members and prepare our comments.

Sincerely,

The Bank Policy Institute

The Independent Community Bankers of America

[1] The Bank Policy Institute is a nonpartisan public policy, research, and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.

[2] The Independent Community Bankers of America® has one mission: to create and promote an environment where community banks flourish. We power the potential of the nation's community banks through effective advocacy, education, and innovation. As local and trusted sources of credit, America's community banks leverage their relationship-based business model and innovative offerings to channel deposits into the neighborhoods they serve, creating jobs, fostering economic prosperity, and fueling their customers' financial goals and dreams. For more information, visit ICBA's website at icba.org.

[3] OCC Bulletin 2026-1, National Bank Chartering: Notice of Proposed Rulemaking (Jan. 8, 2026), https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-1.html.