By urging the OCC to impose stricter regulatory scrutiny, ICBA signaled deep reservations about allowing a blockchain-driven payments company like Ripple to operate under a charter typically associated with conservative fiduciary management. The ICBA concluded its lengthy opposition by stating that approving RTNB’s charter could allow a non-traditional institution to provide deposit-like services without sufficient regulatory supervision, posing risks to consumer protection and the integrity of the banking sector.