The Independent Community Bankers of America sued the Office of the Comptroller of the Currency on October 2, challenging the agency’s authority to grant national trust-bank charters to certain crypto businesses. The complaint, filed in the U.S. District Court for the District of Columbia, also names Comptroller Jonathan Gould in his official capacity.

The lawsuit targets the OCC’s 2026 National Bank Chartering final rule, a 2021 interpretive letter and its conditional approval of Protego Trust Company’s conversion to a national trust bank. ICBA argues that the National Bank Act does not authorize limited-purpose national trust banks that neither take deposits nor perform fiduciary functions.

Those are the plaintiff’s allegations, not a court ruling. ICBA asks for the rule and interpretive letter to be vacated and argues that the challenged actions let crypto firms compete with community banks without facing equivalent regulatory costs.

The distinction between trust banks and ordinary banks matters. As CoinDesk notes, crypto trust institutions do not necessarily offer the conventional cash deposit accounts for which Federal Deposit Insurance Corporation coverage is required. Different business models make comparisons about regulatory obligations more complicated than simply treating every chartered institution as a retail bank.

An OCC spokesperson told CoinDesk that the agency does not comment on litigation.

For digital-asset custody providers, the case puts a federal chartering pathway under judicial scrutiny. The filing itself does not establish that existing charters have been revoked or that crypto custody operations must stop; it begins a legal challenge to the authority underpinning that pathway.