On June 29, 2016, in OneWest Bank, N.A. v. Melina, the US Court of Appeals for the Second Circuit held that a national bank is a citizen only of the state in which its main office is located for purposes of diversity jurisdiction. A national bank is not also a citizen of the state of its principal place of business ( (2d Cir. June 29, 2016)).

OneWest Bank filed a foreclosure action against Robert Melina in the US District Court for the Eastern District of New York. Melina moved to dismiss the action for lack of diversity jurisdiction, arguing that both Melina and OneWest were citizens of New York. OneWest is a national bank with its main office in California. Melina argued that OneWest's principal place of business is in New York and that it should be considered a citizen of that state. The district court disagreed and denied the motion, and Melina appealed.

The Second Circuit affirmed. It joined its sister circuits in holding that a national bank is a citizen only of the state in which its main office is located, which is the office that the bank designates as its headquarters in its articles of association.