ICBA sent a letter to the OCC objecting to the application of Block Inc. to organize Builders Bank & Trust, N.A. as an uninsured national trust bank. ICBA urged the OCC to deny the application because the proposed activities exceed the limited powers authorized for a national trust bank, the proposed ownership structure raises significant supervisory concerns about the accountability of the bank’s ultimate parent, and the public record is insufficient to provide the public with a meaningful opportunity to evaluate and provide comment on the application.