FLOURISH RISING CONCERNS OVER NATIONAL BANK TRUST CHARTERS Over the past few years, we’ve witnessed an alarming upsurge in the number of nonbank financial technology firms applying for national bank trust charters. We can track this trend back to a shift in policy in 2021 (Interpretive Letter #1176) in which the Office of the Comptroller of the Currency (OCC) reinterpreted the trust charter to eliminate its exclusive focus on fiduciary activities and redefined it to create an opening for digital asset firms to apply. By REBECA ROMERO RAINEY, President and CEO, ICBA 6 NEBRASKA INDEPENDENT BANKER
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