SDNY / SOUTH BRONX, Aug 28 –
Zerohash has resubmitted its application for a national
trust bank charter, five weeks after the OCC returned its
original February filing.
The new application, filed August 18 under
a new law firm name quietly fixes the error Inner City
Press documented in the first go-round: the February
filing had listed both CFO Adam Berg and Erik Kiefel as
"Chief Compliance Officer" in the same section, a
discrepancy in a document organizers certified as "true,
correct, and complete" under penalty of federal criminal
statute. This time, only Kiefel is named CCO of the new
entity — though his own bio still describes him, at the
parent company level, as "Deputy Chief Compliance
Officer," a title with no visible superior, and the
"Global Chief Compliance Officer" position Zerohash was
still advertising as recently as July remains, as far as
this filing shows, unfilled.
What didn't change: the application
repeats, word for word, its predecessor's request that the
OCC withhold not just the company's own confidential
materials but "any internal OCC records... of any kind
whatsoever" that so much as reference them — asking the
government to hide its own deliberations, not merely the
applicant's.
There is also the direct claim that the
proposed bank should be exempt from the Community
Reinvestment Act entirely, as a "special purpose bank"
under federal regulation, on the ground that it won't
"grant credit to the public in the ordinary course of
business." Whether a bank built to provide custody,
trading, staking, and settlement infrastructure to
platforms serving retail crypto users fits that narrow
carve-out is, at minimum, a question worth the OCC's
independent scrutiny rather than automatic acceptance.
Inner City Press has asked it to provide that scrutiny,
and has renewed its request for a public hearing. It has
also submitted, and had receipt confirmed of, a FOIA
request, even as its FOIA lawsuit against the Federal
Reserve is pending in SDNY Federal court. Watch this site.
