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OCC Bulletin 2026-1 | January 8, 2026

National Bank Chartering: Notice of Proposed Rulemaking

To

Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies; Department and Division Heads; All Examining Personnel; and Other Interested Parties

Summary

The Office of the Comptroller of the Currency (OCC) is issuing a notice of proposed rulemaking to clarify the longstanding authority of national banks limited to the operations of trust companies and activities related thereto to engage in non-fiduciary activities in addition to their fiduciary activities. The proposal would neither expand nor contract the OCC’s authority to charter a national bank. Comments on all aspects of the proposed rule are due 30 days after it is published in the Federal Register.

Note for Community Banks

The proposed rule would apply to all applicants for a national bank charter that is limited to the operations of a trust company and activities related thereto.

Highlights

The proposal would amend the OCC’s chartering regulation at 12 CFR 5.20 to:

  • align with the OCC’s statutory authorization to charter national banks limited to the operations of a trust company and activities related thereto; and
  • change references from “fiduciary activities” to “operations of a trust company and activities related thereto.”

Further Information

Please contact Christopher Crawford, Acting Assistant Director; or Marjorie Dieter, Counsel; Chief Counsel’s Office, at (202) 649-5490.

 

Adam J. Cohen
Senior Deputy Comptroller and Chief Counsel

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