ICBA submitted a letter to the OCC in strong opposition to the application by Catena Labs, Inc. to establish Catena Trust Bank, National Association, as an uninsured national trust bank. ICBA said the OCC should deny this application as approval would further expand the agency's permissive interpretation of national trust bank authority, facilitate regulatory arbitrage, undermine competitive equity, and expose the federal banking system to novel risks associated with digital assets and stablecoins without sufficient statutory authority or demonstrated public benefit.