ICBA objected to the application of Block Inc. to organize Builders Bank & Trust as an uninsured national trust bank, citing legal, structural, and supervisory concerns.
Details: In a letter to the OCC, ICBA urged the OCC to deny the application, noting:
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The proposed activities exceed the limited powers authorized for a national trust bank.
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The proposed ownership structure raises significant supervisory concerns about the accountability of the bank’s ultimate parent.
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The public record is insufficient to provide the public with a meaningful opportunity to evaluate and provide comment on the application.
ICBA View: ICBA has repeatedly objected to national trust charter applications from firms seeking to engage substantially in non-fiduciary activities.
OCC Rulemaking: After the OCC issued its final chartering rule for national trust banks earlier this year, ICBA called on the OCC to withdraw the proposed rule or reissue an amended proposal consistent with its statutory authority. ICBA last week filed suit challenging the rule as exceeding the agency's statutory authority.
More: An Independent Banker article and ICBA blog post break down the influx of applications from nonbank fintech firms for national bank trust charters and the risks they pose to the financial system.