“Today’s decision by the OCC to approve conditionally a group of novel national trust charters raises important questions about the scope and oversight of these institutions. While innovation in financial services can benefit consumers, it is critical that any chartered entity operates under a regulatory framework that appropriately addresses its activities and risks. We are concerned that expanding the trust charter in this way, particularly for entities that may not engage in traditional fiduciary activities, could blur the lines of what it means to be a bank and create opportunities for regulatory arbitrage. Clear answers are needed to ensure the public and policymakers understand how these charters will be supervised and how risks will be mitigated.”