The Independent Community Bankers of America sued the Office of the Comptroller of the Currency, alleging the OCC lacks authority to charter non-fiduciary crypto firms as national trust banks. The October 2 complaint seeks to invalidate a March 2026 rule, January 2021 guidance and Protego's February 2026 conditional approval. The complaint says the OCC approved or conditionally approved 21 trust banks under the Trump administration, including at least 13 crypto companies. ICBA argues that the GENIUS Act, effective by January 18, 2027, cannot cure charters the OCC has already granted.