Ripple and Circle’s Trust Bank Bids Face Opposition from U.S. Banking Associations

• U.S. banking groups seek more transparency in Ripple and Circle trust bank applications.
• Trade associations call for extended OCC comment periods on crypto trust charter filings.
• Concerns raised over possible OCC policy shift favoring expanded crypto bank activities.

A coalition of major U.S. banking trade groups is opposing a wave of national trust bank charter applications filed by crypto firms, including Ripple and Circle. The American Bankers Association, National Bankers Association, and other groups have sent a formal letter to the Office of the Comptroller of the Currency (OCC), raising concerns about transparency, regulatory gaps, and potential legal overreach associated with these applications.

On July 17, 2025, five national associations representing traditional financial institutions jointly submitted a letter to the OCC’s licensing directors. The letter focuses on applications submitted since April by Ripple National Trust Bank, Circle-affiliated First National Digital Currency Bank, Fidelity Digital Assets, NA, and National Digital TR CO.

According to the associations, public versions of the filings provide insufficient information to allow for meaningful public comment. Specifically, they flagged that Ripple’s application only states it will manage stablecoin reserves and provide related fiduciary services.

Similarly, Circle’s affiliate notes it intends to manage USDC reserves and offer digital asset custody. Fidelity’s filing, meanwhile, includes no public material. The groups argue this lack of transparency restricts public scrutiny, despite the novel legal interpretations these applications may rely on.

The associations are requesting that the OCC extend comment periods and release more detailed descriptions of the applicants’ business models, redacting only genuinely confidential data. They said the aim is to ensure the public has an adequate opportunity to assess potential systemic risks and regulatory implications.

C oncern Over OCC Policy Interpretation

Beyond transparency, the trade groups expressed concern over a possible policy shift at the OCC. They emphasized that national trust banks are traditionally limited to fiduciary activities authorized under 12 U.S.C. § 92a. They warned against allowing such entities to expand into business lines generally restricted to national banks under 12 U.S.C. § 24(Seventh), unless the trust powers statute directly authorizes the activities.

The associations referenced a prior joint letter submitted to the OCC in 2021, in which similar concerns were raised regarding the use of trust charters to gain access to the national banking system without being subject to full regulatory oversight.The comment period for Ripple’s application is set to close on August 4, 2025, while the deadline for Circle ’s affiliate ends July 30. The groups are urging the OCC to delay these deadlines until the requested information is made available to the public.