November 7, 2025
Johnathan V. Gould
Comptroller of the Currency
400 7th St., SW
Washington, DC 20219
Sebastian R. Astrada
Director for Licensing, Midsize, Trust, Credit Card, and Novel Banks
Office of the Comptroller of the Currency
400 7th St., SW
Washington, DC 20219
RE: Public Comment Letter in Opposition to Connectia Trust, National Association Charter Application (2025-Charter-343503)
Dear Director Estrada,
The National Community Reinvestment Coalition (“NCRC”) strongly opposes the application by Sony Bank, Incorporated (“Sony Bank”) for a national trust bank charter under the name Connectia Trust, National Association (“Connectia” or “CTNA”).
NCRC is a coalition of more than 700 community-based organizations that have been fighting for economic justice for almost 30 years. Our mission is to create opportunities for people and communities to build and maintain wealth. NCRC members include community reinvestment organizations, community development corporations, local and state government agencies, faith-based institutions, fair housing and civil rights groups, minority and women-owned business associations, and housing counselors from across the nation. NCRC also partners with many of the nation’s largest national and regional banks to develop Community Benefits Agreements that channel billions of dollars into underserved communities. These partnerships are designed to ensure transparency, accountability, and long-term impact. NCRC’s Innovation Council brings together leaders from financial technology companies to explore innovative, inclusive financial solutions. Each of these networks and partnerships serve as collaborative spaces where stakeholders can share insights, develop strategies, and promote equitable access to financial services.
A national trust charter would enable CTNA to hold consumer funds, offer custodial services, and manage settlements nationwide. The OCC must reject Sony Bank’s application for a national trust bank charter for CTN due to ongoing and serious concerns about the OCC’s chartering authority, regulatory arbitrage that will harm communities and consumers, systemic risk and mounting fraud concerns.
1 The OCC does not have authority to issue national trust bank charters to crypto and stablecoin companies.
The OCC charters national banks under the authority of the National Bank Act of 1864, as amended.[1] Federal regulations detail the factors and principles that the OCC will consider when reviewing charter applications. The Comptroller’s Licensing Manual further details the considerations involved in the chartering process.[2]
In reviewing charter applications for national banks, the factors and principles that the OCC must consider include[3]:
- Maintaining a safe and sound banking system;[4]
- Encouraging a national bank to provide fair access to financial services by helping to meet the credit needs of its entire community;[5]
- Ensuring compliance with laws and regulations;[6] and
- Promoting fair treatment of customers, including efficiency and better service.[7]
In addition, federal regulations detail the policy considerations that the OCC accounts for when evaluating an application to establish a national bank. The OCC considers whether the proposed institution:
- Has organizers who are familiar with national banking laws and regulations or Federal savings association laws and regulations, respectively;[8]
- Has competent management, including a board of directors, with ability and experience relevant to the types of services to be provided;[9]
- Has capital that is sufficient to support the projected volume and type of business;[10]
- Can reasonably be expected to achieve and maintain profitability;[11]
- Will be operated in a safe and sound manner;[12] and
- Does not have a title that misrepresents the nature of the institution or the services it offers.[13]
The OCC’s recent consideration of limited-purpose national trust charters for stablecoin issuers and other fintech firms exceeds the agency’s authority under the National Bank Act. Connectia is not a trust company but is seeking to engage in core banking activities, including facilitating payments and taking deposits, without obtaining deposit insurance or becoming subject to consolidated Federal Reserve supervision: “granting these firms limited-purpose trust charters would blur the statutory boundaries of what constitutes a “bank,” undermine the credibility of the national charter, and heighten systemic risk by allowing them to operate under a lighter regulatory regime.”[14]
In evaluating Connectia’s trust charter application, the OCC must consider the full range of statutory and prudential factors set forth in 12 C.F.R. § 5.13(b) and section 6 of the Federal Deposit Insurance Act[15]; the OCC may deny the application if significant supervisory, CRA (if applicable), or compliance concerns exist. These factors include whether the applicant presents significant supervisory, compliance, or Community Reinvestment Act (CRA) [16] concerns, and whether its proposed activities are consistent with the purposes of the Federal Deposit Insurance Act, the National Bank Act, and the Home Owners’ Loan Act. As noted above, Connectia’s proposed activities are not consistent with the purposes of the National Bank Act. The OCC does have the authority to grant this entity a national trust bank charter.
2 Granting a national trust bank charter to Connectia would enable regulatory arbitrage that harms communities and consumers.
A national trust charter would provide Connectia with the reputational benefits, enhanced market credibility, and federal regulatory status of a banking institution while allowing it to avoid many of the fundamental obligations that justify such privileges. This arrangement would create dangerous imbalances in four areas: community investment responsibilities, consumer protection standards, regulatory oversight and accountability, and systemic risk management. Any form of national bank charter is a privilege, accompanied by obligations to communities and consumers. Approving Connectia’s application would create a two-tier system where digital asset firms receive comparable federal status without comparable public obligations, undermining the integrity of the entire chartering framework.
The US has a well-established legal and regulatory framework that governs banks and banking activities. This framework exists to ensure strong consumer protections, including transparency around fees and privacy; rigorous anti-money laundering (AML) and counter-terrorism financing requirements; fraud prevention and reporting obligations; deposit insurance to protect consumers’ funds; and the overall safety and soundness of the U.S. financial system. Issuing national trust bank charters to crypto and stablecoin companies would create regulatory arbitrage, weaken public trust, and expose consumers and markets to unnecessary risk.
2.1 Lost Reinvestment to Communities and the Need for Community Development Obligations
National trust banks are not subject to Community Reinvestment Act (CRA) requirements, meaning Connectia – an entity that proposed to engage in some traditional banking services such as taking and holding consumer deposits – would gain the prestige and benefits of a federal charter without any obligation to serve low- and moderate-income communities or meet local credit needs. Traditional banks must demonstrate how they reinvest deposits back into their communities—Connectia would face no such requirement. Connectia’s involvement in stablecoin issuance means a trust charter would legitimize diverting potentially billions of dollars from community bank deposits into stablecoins held by an entity with no corresponding community reinvestment obligation. This diversion of capital away from community reinvestment represents a fundamental departure from the principle that federally chartered institutions should serve public purposes, not merely private profit.
The CRA states that banks which benefit from federal deposit insurance have an obligation to meet the credit needs of entire communities, meaning that banks cannot solely serve the wealthiest customers. They must serve the needs of low- and moderate-income households as well. Stablecoin issuers should be held to CRA-like standards as they will also rely on a supervisory regime that assures consumers that stablecoins are sound ways to store money.
Until stablecoin legislation requires stablecoin issuers to reinvest a portion of their proceeds into community development projects in underserved communities, no stablecoin issuer should receive any form of bank charter. Traditional deposit insurance is a form of public subsidy to the banking industry and will grant the patina of legitimacy to a national trust bank even if it is, in form but not substance, only providing custodial services, in exchange for which banks accept obligations to the public interest. The same exchange should apply to stablecoin issuance.
Applying community development obligations to stablecoin issuers would drive billions of dollars into needed community and economic development projects and initiatives. In 2023 alone, banks originated over $127 billion in loans that meet the CRA’s definition of community development for LMI communities and households. In addition, ensuring community development conditions are being met by nonbank or national trust bank issuers would also allow for a more level playing field between banks, especially community banks – and nonbank or national trust bank issuers.
2.2 Threat of Consumer Harm
As noted in several comment letters submitted earlier this year by NCRC, granting a national trust bank charter to crypto and stablecoin companies threatens to harm consumers on multiple levels.
Consumers using stablecoins issued by a “national trust bank” would not have protections that federally insured deposits offer; however, the trust bank charter will confer the appearance of regulatory legitimacy and safety, which is likely to mislead and confuse consumers. This perception gap increases public exposure to financial loss while allowing Connectia to benefit from the reputational privileges of the federal banking system without offering the core protections that actual banks provide.
In addition, a stablecoin issuer taking consumer deposits under a national trust bank charter would not be subject to the OCC’s National Bank Charges regulation, which requires full-service banks to consider key consumer protection principles when setting fees. A federal trust charter would also preempt state-level money transmitter licenses and consumer protection laws that would currently apply to Connectia’s operations in many jurisdictions. This federal preemption could weaken consumer protections that states have enacted specifically for digital asset activities. Trust banks aren’t FDIC-insured, but the “national bank” label could mislead consumers into expecting federal protection, creating moral hazard and exposing them to avoidable harm.
3 Granting a national trust bank charter to any stablecoin issuer creates systemic risk.
Traditional banks that maintain community reinvestment programs, robust compliance infrastructure, and comprehensive consumer protections would face a competitive disadvantage against Connectia operating under a lighter trust charter while enjoying comparable market credibility. This regulatory arbitrage allows Connectia to gain federal banking status while avoiding the obligations and safeguards that justify such privileges. The OCC should not permit Connectia to use a trust charter as a regulatory shortcut to avoid state-level oversight while lacking the responsibilities and protections of insured banking institutions. The resulting competitive distortion could trigger a race to the bottom, incentivizing other institutions to seek similar arrangements. Moreover, granting federal banking status to an entity with Connectia’s unsettled risk profile, particularly one involved in stablecoin issuance that could scale to trillions of dollars, introduces systemic risk without corresponding safeguards, deposit insurance, or resolution mechanisms that protect depositors when traditional banks fail.
3.1 Risks to Safety and Soundness and Government Bailout
Despite the passage of the GENIUS Act, federal regulators have yet to finalize this law’s implement regulations, which will be critical to establish clear rules for stablecoins, leaving critical issues of backing, redemption, and oversight in regulatory limbo. Even after the GENIUS Act and its implementing regulations all go into effect, which could take several years, legal scholar Art Wilmarth warns that “By placing the federal government’s seal of approval on uninsured and weakly-regulated nonbank stablecoins, the GENIUS Act would greatly increase the likelihood that future runs on stablecoins would trigger systemic financial crises and require costly government bailouts.”[17]
Granting Connectia a trust bank charter before a comprehensive regulatory framework is in place would expose both consumers and the broader financial system to poorly understood risks. Connectia’s proposed banking operations would create an unprecedented moral hazard by extending the federal safety net to a company whose core business involves highly volatile digital assets. Stablecoin issuers like Connectia operate profit-driven business models that make them uniquely susceptible to runs in the absence of appropriate risk management standards.[18]
3.2 Separation of Banking and Commerce
In the United States, bright lines have existed to separate banking from commerce. The separation of banking and commerce is critical to maintaining the safety and soundness of our financial system. The national trust bank charter is a problematic contradiction to that principle. If Connectia receives a charter, its parent company will not be subject to the Bank Holding Company Act, and regulators will have little insight into its corporate parent’s operations even though they have many interdependent relationships.
4 The OCC must place a moratorium on all stablecoin company charter applications until laws and regulations can effectively address safety and soundness concerns and protect consumers against fraud.
The current regulatory framework governing cryptocurrency and stablecoin is not sufficient to avoid massive fraud and financial losses, nor does it adequately address stablecoin liquidity standards, reserve requirements, or consumer protection.
The digital asset ecosystem that Connectia operates in has been plagued by fraud, hacking, and cybercrime, with billions of dollars in losses annually. US consumers are already losing billions of dollars a year to fraud, with stablecoins overtaking Bitcoin as the illicit currency of choice for criminals.
According to the FBI’s Internet Crime Complaint Center (IC3) 2024 Internet Crime Report, US consumer losses due to scams are increasing at a startling rate, rising from just under $4 billion in 2020, to over $16 billion in 2024.[19] Cryptocurrency has become the top way that complainants reported financial loss in fraud, accounting for $9.3 billion dollars in losses in 2024 alone.[20] As a group, those over the age of 60 suffered the most losses and submitted the most complaints referencing cryptocurrency.[21] While Bitcoin was the currency of choice for cybercriminals for years, this changed in 2022: a 2025 report shows a seismic shift to stablecoins that now account for 63% of all illicit crypto transactions.[22]
In June of this year, the Financial Action Task Force (FATF), a leading global financial crime watchdog, recently called on countries to take stronger action to combat illicit finance in crypto
assets, warning that gaps in regulation could have global repercussions.[23]
A related area of concern involves Sony’s proposed Connectia Trust and its potential connection to the broader digital-asset and payments infrastructure. Like other stablecoins and cryptocurrencies, this infrastructure enables widespread cryptocurrency-kiosk fraud, a fast-growing consumer-protection crisis that disproportionately harms seniors and vulnerable individuals. While Sony and its affiliates do not directly operate crypto kiosks, Sony Bank and other Sony Group divisions have tested stablecoin issuance, digital-wallet platforms, and decentralized-finance (DeFi) applications with the Japanese Financial Services Agency, including a 2024 proof-of-concept for automated market-maker functionality. These activities demonstrate Sony’s intent to expand into digital-asset custody, stablecoin settlement, and tokenized payments—functions that could make Connectia Trust an indirect liquidity or settlement provider to kiosk and exchange networks. Given the absence of any U.S. supervisory history for Sony’s financial affiliates, the OCC should closely evaluate whether the firm’s anti-money-laundering, sanctions, and transaction-monitoring controls can detect the transactional patterns typical of kiosk-related fraud.
Recent federal and state data underscore the scale of this threat posed by stablecoin and crypto-kiosk fraud. The Federal Trade Commission reported that consumers lost over $65 million to Bitcoin ATM scams in the first half of 2024, with a median individual loss of $10,000, and that older adults were several times more likely to be targeted.[24] FinCEN and multiple state attorneys general have documented that kiosks have been used to launder “millions” in criminal proceeds, prompting a wave of new state laws imposing transaction caps, disclosure mandates, refund rights, and operator registration requirements.
If granted a national trust charter, Connectia Trust could invoke federal preemption to bypass emerging state-level consumer-protection regimes governing crypto kiosks, even while serving as a settlement or stablecoin-reserve provider supporting retail-facing digital-asset platforms. Given Sony’s global reach, brand credibility, and expanding fintech footprint, such preemption could erode state safeguards precisely as new protections are being enacted to curb fraud.
Finally, the OCC should also deny all stablecoin company charter applications until the Secretary of the Treasury has finalized rules to implement Section 5(A) of the GENIUS Act. That section of the Act provides that a permitted payment stablecoin issuer shall be treated as a financial institution for purposes of the Bank Secrecy Act, and as such, shall be subject to all federal laws applicable to a financial institution located in the United States relating to economic sanctions, prevention of money laundering, customer identification, and due diligence.
Before the OCC considers granting a charter to any stablecoin issuer, the following rules and regulations implementing provisions of the GENIUS Act must be in place:
- The Federal Reserve Board is authorized to issue regulations related to reserve requirements and liquidity standards for federally regulated stablecoin issuers.[25]
- The Federal Deposit Insurance Corporation may issue rules to ensure that insured depository institutions issuing stablecoins comply with capital and risk management standards.[26]
- The Department of the Treasury is authorized to issue rules on consumer protection, including public disclosures of reserve composition, redemption procedures and prohibited marketing practices.[27]
- The Financial Crimes Enforcement Network is authorized to issue implementing regulations under the Bank Secrecy Act to ensure anti-money laundering and sanctions compliance by stablecoin issuers.[28]
- The Secretary of the Treasury is granted broad authority to issue rules and guidance necessary to carry out the act.[29]
5 The comment period for charter applications must be extended to at least 90 days.
A key feature of the American democratic process is the opportunity for public engagement in the lawmaking process and in the American banking law this means the public’s right to participate by submitting comments on charter applications. A 30-day comment period for national trust applications is simply not sufficient for meaningful public engagement.
We urge the OCC to publicize the nonpublic portions of all stablecoin issuer charter applications (redacting any nonpublic personal information about the proposed entities’ officers or directors). Finally, we request that the OCC extend the comment periods for all such applications to 90 days.
Conclusion
The OCC must reject Connectia’s application for a national trust bank charter. Granting a national trust bank charter to Connectia would enable regulatory arbitrage, reduce community development, risk significant harm to consumers and communities, and would create systemic risk.
Finally, until the GENIUS Act is effective and its implementing regulations are finalized, the OCC must not grant any stablecoin companies a national trust bank charter – doing so would create systemic risk and fuel a steep increase in illicit finance and fraud that are already wreaking havoc on U.S. consumers.
Thank you for considering this request. If you have any questions about this letter, please contact me at jvantol@ncrc.org.
Sincerely,
Jesse Van Tol
President & Chief Executive Officer
NCRC
[1] 12 U.S.C. 1 et seq.
[2] Office of the Comptroller of the Currency. Comptroller’s Licensing Manual: Charters. December 2021. https://www.occ.gov/publications-and-resources/publications/comptrollers-licensing-manual/files/charters.pdf
[3] 12 C.F.R. s. 5.20(e).
[4] 12 CFR 5.20(f)(1)(i)
[5] 12 CFR 5.20(f)(1)(ii)
[6] Ibid.
[7] Ibid.
[8] 12 CFR 5.20(f)(2)(i)(A)
[9] 12 CFR 5.20(f)(2)(i)(B)
[10] 12 CFR 5.20(f)(2)(i)(C)
[11] 12 CFR 5.20(f)(2)(i)(D)
[12] 12 CFR 5.20(f)(2)(i)(E)
[13] 12 CFR 5.20(f)(2)(i)(F)
[14] Bank Policy Institute. (2023, November 2). BPI urges OCC to preserve the integrity of national trust charters. BPI. https://bpi.com/bpi-urges-occ-to-preserve-the-integrity-of-national-trust-charters/
[15] 12 U.S.C. 1816
[16] Ibid., 4.
[17] Open Banker, “Congress Must Reject the GENIUS Act and Remove the Dangers Posed by Nonbank Stablecoins” by Art Wilmarth: https://ourfinancialsecurity.org/wp-content/uploads/2025/07/AFR-Factsheet.GENIUS-Acts-Flaws-and-Failures.pdf
[18] Financial Stability Oversight Council, 2024 Annual Report (Washington, DC: U.S. Department of the Treasury, 2024), 8, https://home.treasury.gov/system/files/261/FSOC2024AnnualReport.pdf.
[19] Federal Bureau of Investigation, 2024 Internet Crime Report (Washington, DC: Internet Crime Complaint Center, 2025), 7, https://www.ic3.gov/AnnualReport/Reports/2024_IC3Report.pdf.
[20] Ibid., 3.
[21] Ibid., 35.
[22] Chainalysis, “2025 Crypto Crime Report: Illicit Volumes Portend Record Year as On-Chain Crime Becomes Increasingly Diverse and Professionalized,” January 15, 2025, https://www.chainalysis.com/blog/2025-crypto-crime-report-introduction/
[23] Reuters, “Global financial crime watchdog calls for action on crypto risks,” June 25, 2025, https://www.reuters.com/sustainability/boards-policy-regulation/global-financial-crime-watchdog-calls-action-crypto-risks-2025-06-26/
[24] Federal Trade Commission, “New FTC Data Shows Massive Increase in Losses to Bitcoin ATM Scams,” press release, September 3, 2024, https://www.ftc.gov/news-events/news/press-releases/2024/09/new-ftc-data-shows-massive-increase-losses-bitcoin-atm-scams
[25] GENIUS Act, Sec. 4(e)(2), S.1582, 119th Cong.
[26] GENIUS Act, Sec. 4(e)(3), S.1582, 119th Cong.
[27] GENIUS Act, Sec. 6(a)–(c), S.1582, 119th Cong.
[28] GENIUS Act, Sec. 7(b), S.1582, 119th Cong.
[29] GENIUS Act, Sec. 13(a), S.1582, 119th Cong.
