Cite as: 522 U. S. 479 (1998)
Opinion of the Court
theless establish that we should not inquire whether there has been a congressional intent to benefit the would-be plaintiff. In Data Processing, supra, the Office of the Comptroller of the Currency (Comptroller) had interpreted the National Bank Act's incidental powers clause, Rev. Stat. § 5136, 12 U. S. C. § 24 Seventh, to permit national banks to perform data processing services for other banks and bank customers. See Data Processing, supra, at 151. The plaintiffs, a data processing corporation and its trade association, alleged that this interpretation was impermissible because providing data processing services was not, as was required by the statute, "[an] incidental powe[r] . . . necessary to carry on the business of banking." See 397 U. S., at 157, n. 2.
In holding that the plaintiffs had standing, we stated that § 10(a) of the APA required only that "the interest sought to be protected by the complainant [be] arguably within the zone of interests to be protected or regulated by the statute . . . in question." Id., at 153. In determining that the plaintiffs' interest met this requirement, we noted that although the relevant federal statutes—the National Bank Act, 12 U. S. C. § 24 Seventh, and the Bank Service Corporation Act, 76 Stat. 1132, 12 U. S. C. § 1864--did not "in terms protect a specified group[,] . . . their general policy is apparent; and those whose interests are directly affected by a broad or narrow interpretation of the Acts are easily identifiable." Data Processing, 397 U. S., at 157. "[A]s competitors of national banks which are engaging in data processing services," the plaintiffs were within that class of "aggrieved persons" entitled to judicial review of the Comptroller's interpretation. Ibid.
Less than a year later, we applied the "zone of interests" test in Arnold Tours, Inc. v. Camp, 400 U. S. 45 (1970) (per curiam) (Arnold Tours). There, certain travel agencies challenged a ruling by the Comptroller, similar to the one contested in Data Processing, that permitted national banks to operate travel agencies. See 400 U. S., at 45. In holding
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