ICBA submitted a letter to the OCC opposing the application filed by EDX Markets Holding Company Inc. to charter EDX Trust, National Association as a national trust bank. ICBA urged the OCC to deny the application and said it has three overarching concerns: The proposed business model exceeds traditional trust powers; the charter structure enables regulatory arbitrage; and the OCC’s accelerating pace of approvals and policy changes outstrips its capacity for deliberate and transparent policymaking.