Banking and Finance Law Daily Wrap Up, BANKING OPERATIONS—ICBA opposes Dakota Ridge National Trust Bank Charter Application, (Aug 31, 2026)

By Donielle Tigay Stutland, J.D.

ICBA urges the OCC to deny Dakota Ridge’s application for a national trust bank charter, citing concerns with its business model and broader policy considerations.

The Independent Community Bankers of America (ICBA) sent a letter to the Office of the Comptroller of the Currency (OCC) in opposition to the application filed by Dakota Ridge, Inc. (“Dakota Ridge” or “the Applicant”) for a national trust bank charter, Dakota National Trust Bank (“DNTB” or the “Bank”). In a letter written by Joseph Chaves, Senior Director, Safety & Soundness Regulatory Policy, ICBA urges the agency to deny the recently submitted application for a national trust bank charter, citing concerns with the Bank’s business model and broader policy considerations. At a minimum, ICBA requests that the OCC should defer action until the applicant provides sufficient public information to permit a meaningful review of the Application’s legal, safety and soundness, and competitive implications.

On July 28, 2026, Dakota Ridge, a Colorado-based stable-coin infrastructure company, submitted a national trust bank charter application to the OCC to form Dakota National Trust Bank, which would be based in New York and issue stablecoins (the “application”). Dakota operates in the United States and offers stablecoin-related services through money transmission licenses.

In the application, Dakota indicated that upon opening, DNTB will (1) offer a digital asset custody service as a fiduciary, (2) issue U.S. dollar-denominated stablecoins, and (3) provide related services, including customer-directed transactional services.

Opposition letter. The ICBA detailed several reasons why it opposes the application. First, ICBA argues that the proposed business model “exceeds traditional trust powers and raises fundamental supervisory concerns.” ICBA also argues that “OCC lacks statutory authority to charter a national trust bank engaging in non-fiduciary activities.” ICBA cited the statutory text and legislative history of the National Bank Act to stress that “National Trust Banks are authorized solely to exercise fiduciary powers” and that they are limited purpose institutions chartered under 12 U.S.C. 27(a) to conduct the “operations of a trust company and activities related thereto.” Moreover, the letter notes that, national trust banks may not engage in the “business of banking,” that is reserved for full-service national banks. The ICBA asserts that the activities of DNTB listed in the application are a “far broader range of activities than the classic fiduciary functions.”

ICBA next argues that the application fails to show how DNTB would be “meaningfully independent from its parent.” Several of the proposed organizers, directors, and senior executive officers of DNTB are current Dakota executives. The chair of DNTB’s board, Ryan Bozarth, is Dakota’s Chief Executive Officer and would also serve as DNTB’s President, Chief Trust Officer, and Chair of DNTB’s board of directors. Moreover, ICBA highlights that the application does not explain how the Bank would manage conflicts, affiliate transactions, or independent fiduciary judgment.

Next, ICBA indicates that the application fails to establish that the proposed board and management team have sufficient banking and trust-banking experience. The proposed board is largely drawn from technology, fintech, digital assets, product development, and startup sectors, with limited federally regulated banking or trust-bank experience.

ICBA also suggests that the public record does not permit meaningful evaluation of DNTB’s ability to satisfy the convenience and needs of the community. DNTB proposes to operate from a single office in New York while offering fiduciary digital-asset custody, issuing U.S. dollar-denominated stablecoins, and providing unspecified “customer-directed transactional services.” However, ICBA argues that the application does not publicly identify the customers or markets DNTB principally intends to serve, describe the financial services needs its proposed activities would address, or explain the public benefits that would result from granting the charter.

Further, the letter suggests that the Applicant seeks to “use regulatory arbitrage to gain bank-like powers without bank-like obligations.” ICBA says it will distort competition if DNTB is allowed to conduct bank-like activities through an uninsured national trust bank charter. DNTB seeks to issue U.S. dollar-denominated stablecoins, products that function much like demand deposits because they are designed to be readily transferable, redeemable at par, and integrated into payment systems. ICBA avers the Bank would receive the benefits of a national bank charter, such as nationwide preemption, without the corresponding supervisory and regulatory requirements that apply to community banks.

Finally, ICBA urges the OCC to pause the application given that it does not provide enough information for “meaningful” public review. Wrote the trade group, “The public portion of the application is so sparse that it is functionally impossible for the public to conduct meaningful review of DNTB’s proposed operations. Aside from the three types of activities quoted above, Dakota’s application does not disclose the nature or scope of DNTB’s planned activities in any meaningful detail. The business plan, financial projections, and technology plans have been submitted in their entirety as confidential.”

Companies: Dakota Ridge, Inc.; Dakota National Trust Bank; Independent Community Bankers of America

RegulatoryActivity: BankingOperations BankHolding ColoradoNews