June 30, 2025

Letter Opposing the Application of National Digital Trust Company to Form a National Trust Bank

ICBA sent a letter to the OCC objecting to the decision to expand national trust bank powers through Interpretive Letter #1176 without formal rulemaking.

ICBA pointed out the Bank Holding Company Act exemption, discussed the danger of allowing national trust banks to blur the line between banking and commerce, and detailed the significant risks in digital asset custody.