BPI Opposes OCC’s Consideration of Connectia Trust’s Application for a National Trust Bank Charter

Dear Mr. Astrada:

The Bank Policy Institute^[1] respectfully submits this comment in opposition to the application submitted by Connectia Trust, National Association ("Trust Bank") on October 7, 2025 (the "Application") to the Office of the Comptroller of the Currency seeking approval for a national trust bank charter.^[2]

As we describe in detail below, we have deep concerns that approval of the Application, whether alone or in conjunction with the similar applications recently filed: (i) raises questions regarding the longstanding precept underlying financial regulation in the United States maintaining the separation of banking and commerce; (ii) would exceed the scope of the OCC's authority under 12 U.S.C. 27(a), which limits national trust bank charters to institutions predominantly engaged in trust and fiduciary activities; (iii) would permit the national trust bank charter to be used in a new and untested manner that could significantly increase risks to the U.S. financial system; and (iv) would create an unlevel playing field that would harm traditional federal- and state-chartered banks and inhibit their ability to serve the credit needs of their communities.

We also note that the public's ability to meaningfully comment on the Application is significantly limited by the fact that the portions of the Application that the OCC has made public include only a cursory and superficial description of the Trust Bank and its proposed activities - literally no more than a few sentences. We filed a Freedom of Information Act request for the Application and all exhibits. As of the date of this letter, we have not received a response to our request. While we submit this comment based on the information available, we note that neither the Applicant nor the OCC has provided the public with adequate information for the public to meaningfully assess or fully comment on Trust Bank's proposed activities or business plan or to consider any relevant legal or policy issues that may be presented by such activities. While the Application refers to a confidential business plan appended to the Application which would provide helpful information, this information remains hidden from the public. This lack of transparency is wholly inconsistent with the present administration's explicit commitment to this principle^[3] As discussed in more detail below, the Application raises a host of important legal, regulatory, and policy questions and concerns that we urge the OCC to carefully evaluate and ensure are appropriately answered and addressed before any action is taken on the Application.

To read the full comment letter, click here, or click on the download button below.

[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations and represents the financial services industry with respect to cybersecurity, fraud and other information security issues.

[2] The Application largely mirrors numerous other applications recently filed by affiliates of entities engaged primarily in activities related to digital assets, in response to which we have submitted similar comments.

[3] Approving the Application without affording the public visibility into Trust Bank's proposed activities would contravene President Trump's express mandates regarding transparency in government. As described in a White House announcement, "President Trump campaigned on a promise to return power back to the American people by 'cleaning out the Deep State.'" https://www.whitehouse.gov/issues/doge/. Without greater transparency and solicitation of public input regarding the Application and the OCC's interpretation of its chartering authority, President Trump's promise would remain unfulfilled. Accordingly, we ask the OCC to release additional information to the public on Trust Bank's business plans, with only strictly necessary redactions, to provide the public the ability to scrutinize such information.