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The Full Complaint [PDF]

CSBS filed a complaint in the U.S. District Court of D.C. against the OCC, seeking to prevent the agency from its unlawful attempt to create a national nonbank charter. A national nonbank charter will harm markets, innovation, and consumers.


  • The OCC has gone far beyond the limited authority granted to it by Congress under the National Bank Act and other federal banking laws
  • Those laws authorize the OCC to only charter institutions that engage in the “business of banking,” which under the National Bank Act requires an institution, at minimum, to receive deposits.  Yet the OCC is attempting to create a new special purpose charter for nonbank companies that do not take deposits, without express statutory authorization.
  • The OCC does not have the authority to create a special purpose charter for nonbanks without specific congressional approval.