ICBA sent a letter to the OCC objecting to the Aug. 18 application by ZeroHash National Trust Bank to organize as a de novo national trust bank. ICBA urged the OCC to deny the application because ZNTB’s proposed activities are not permissible for a national trust bank, adding that, at a minimum, the OCC should defer action unless and until it addresses supervisory, managerial, operational, and affiliate-dependence issues.