The National Community Reinvestment Coalition (NCRC) believes that the lawsuit filed by the Independent Community Bankers of America (ICBA) against the Office of the Comptroller of the Currency (OCC) raises a fundamental question: should digital asset companies be able to obtain the benefits of a federal bank charter while avoiding core obligations that apply to traditional banks?

"This is exactly the two-tier system NCRC has warned about," said NCRC's President and CEO Jesse Van Tol. "Bank charters, regardless of form, should come with strong obligations to serve communities."

NCRC has repeatedly warned that the OCC's national trust bank framework risks creating a two-tier banking system where digital asset companies gain the credibility and advantages of a federal charter without Community Reinvestment Act obligations or federal deposit insurance requirements.

Bank charters should not be treated as routine approvals. Regulators should carefully examine whether applicants are financially sound, have the appropriate managerial resources to comply with the law and have credible business plans to operate safely. Regulators should only grant charters within the authority Congress has given them. New technology is not an excuse for shortcuts around the law.

The OCC has a responsibility to the public when it grants a federal bank charter. It must carefully review applications, follow the limits Congress set and make sure the applicants can operate safely and lawfully. Specialty charters , like national trust bank charters , deserve real scrutiny, including attention to their impact on low- and moderate-income communities.

"The OCC should not create a back door into banking that lets crypto companies gain the benefits and public trust that come with a bank charter while communities lose the protections and investment obligations that should come with it," Van Tol said.

Here are links to several NCRC comment letters on national trust bank charter applications:

NCRC Comment in Opposition to Coinbase National Trust Charter Application

NCRC Comment on Application of Kraken, a Crypto Exchange, for a National Trust Bank Charter

NCRC Letter in Opposition to the Formation of Payo Digital Bank

NCRC's Comment On World Liberty Trust Company National Trust Bank Charter Application

NCRC and Three Dozen Community Groups Oppose National Trust Bank Charter for Stablecoin Issuer Circle

NCRC Continues Opposition to National Trust Bank Charters for Stablecoin Issuers with Comment on Ripple Charter Application

NCRC Comment in Opposition to Crypto.com's National Trust Charter Application