In Clarke v. Securities Industry Assn., 479 U.S. 388 (1987), a securities dealers trade association sued the Comptroller, this time for authorizing two national banks to offer discount brokerage services both at their branch offices and at other locations inside and outside their home States. See id., at 391. The plaintiff contended that the Comptroller's action violated the McFadden Act, which permits national banks to carry on the business of banking only at authorized branches, and to open new branches only in their home States and only to the extent that state-chartered banks in that State can do so under state law. See id., at 391-392. The Court held that the plaintiff had standing under the APA. Summarizing our prior holdings, we stated that although the "zone of interests" test "denies a right of review if the plaintiff's interests are . . . marginally related to or inconsistent with the purposes implicit in the statute," id., at 399, "there need be no indication of congressional purpose to benefit the would-be plaintiff," id., at 399-400 (citing ICI ). The Court then determined that by limiting the ability of national banks to do business outside their home States, "Congress had shown a concern to keep national banks from gaining a monopoly control over credit and money." 479 U.S., at 403. The interest of the securities dealers in preventing national banks from expanding into the securities markets directly implicated this concern because offering discount brokerage services would allow national banks "access to more money, in the form of credit balances, and enhanced opportunities to lend money, viz., for margin purchases." Ibid. The case was thus analogous to Association of Data Processing Service Organizations, Inc. v. Camp, 397 U.S. 150, 152 (1970) and ICI: "In those cases the question was what activities banks could engage in at all; here, the question is what activities banks can engage in without regard to the limitations imposed by state branching law." 479 U.S., at 403.