Create new financial firm charters trading activity limits for higher equity standards

Research notes

Chapter 22’s major items on the same printed page — #1981 (merge the OCC, FDIC, NCUA and the Fed’s supervisory functions) and #1983 (repeal Dodd-Frank titles I, II and VIII) — are both not started with no Evidence, and this item shares their negative search on structural banking legislation.

• Scan triage 2026-10-05 (thirteenth run): checked, does not reach. Independent Community Bankers of America v. OCC (D.D.C., filed 2026-10-02) challenges the OCC’s final rule National Bank Chartering (FR 2026-04088, 2026-03-02). The rule was published before this item’s 2026-08-31 search and the search did not name it. By its abstract it lets “national banks limited to the operations of trust companies” engage in non-fiduciary activities as well. The complaint’s exhibits are that rule, Interpretive Letter 1176 and the Protego conditional charter approval. This is the nearest instrument: it loosens the activity limits of an existing charter class. It attaches no equity or risk-retention standard and creates no new class, so the Quote’s bargain (fewer restrictions in return for higher equity) is not there. The not started event’s sentence “no banking agency has proposed such a charter by rule” stands. The rule was read by abstract only. https://www.federalregister.gov/documents/2026/03/02/2026-04088/national-bank-chartering

Queries: bills.ndjson titles for charter (no financial-firm charter bill among 20 hits, all education, gold-medal or corporate-charter measures); Federal Register corpus for OCC and Federal Reserve rules proposing a new charter class; the Treasury press and statements indexes 2025-2026.