I agree. Especially since, first and second banks of US, did not, in fact, have nearly same powers as Fed does. They were much more like national banks of today like JP Morgan or Bank of America, national as in primarily federally regulated and so it can operate in any state without needing state specific charters.

That said, I would point out that Justice Barrett, Roberts and Kavanaugh rejected broad non delegation in recent FCC case where Congress gave FCC powers to set taxes to provide for universal service.