- Stablecoin infrastructure firm Rain has filed an application with the OCC to form Rain National Trust Bank, a New York-headquartered national trust bank.
- Led by proposed CEO Brandon Soto, the entity would hold institutional assets in fiduciary custody and support dollar-backed stablecoin issuance under the $GENIUS Act without offering retail loans or taking deposits.
- The move comes amid escalating industry friction, as the Independent Community Bankers of America (ICBA) filed a federal lawsuit challenging the OCC’s framework for digital-asset trust charters.
Rain Seeks OCC Approval for National Trust Bank Charter
Stablecoin payments infrastructure provider Rain has formally submitted an application to the Office of the Comptroller of the Currency (OCC) to establish a national trust bank in the United States. Filed on Monday, October 5, 2026, the application seeks approval to create Rain National Trust Bank, an entity that would be headquartered in New York. Under the proposed structure, the institution will provide fiduciary custody for digital assets and U.S. dollars on behalf of institutional clients, manage reserve assets for authorized stablecoin issuers, and handle the issuance and redemption of dollar-backed stablecoins in accordance with the $GENIUS Act.
Currently, Rain builds settlement rails—such as cards, digital wallets, and payment transfers—for enterprise customers, relying on external third-party partners to handle underlying custody and token issuance. Securing a national trust bank charter would allow the firm to bring these operations in-house under unified federal oversight. Unlike self-custody arrangements, where organizations hold their own private cryptographic keys without supervision, trust bank custody requires direct compliance with federal examiners. Rain plans to run the bank as a distinct subsidiary focused strictly on stablecoin and digital asset infrastructure; it will not offer consumer bank accounts, accept commercial deposits, or issue corporate loans.
Executive Leadership and Fiduciary Strategy
Pending OCC review and approval, former Square Financial Services Chief Financial Officer Brandon Soto is slated to take the helm as president and chief executive officer of Rain National Trust Bank. According to Rain Chief Executive Officer and Co-Founder Farooq Malik, the transition toward a federally chartered institution reflects direct demand from enterprise clients who require heightened regulatory compliance. Farooq Malik stated that institutions developing products on the platform want their program assets held by a fiduciary that “answers to a federal regulator.”
The push by Rain underscores an ongoing wave of fintech and digital-asset firms seeking national banking frameworks. On the very same day Rain submitted its filing, payments infrastructure provider Modern Treasury also announced that it had applied for regulatory approval to launch digital asset custody and corresponding fiat banking services, signaling intense momentum across the financial infrastructure ecosystem.
Legal Blowback: Community Bankers Challenge OCC Authority
Rain’s application lands in the middle of a sharp legal confrontation between legacy financial institutions and federal regulators. On Friday, October 2, 2026, the Independent Community Bankers of America (ICBA) launched a lawsuit against the OCC and Comptroller Jonathan Gould in the U.S. District Court for the District of Columbia. The trade association claims the OCC has overstepped its statutory limits by permitting non-depository national trust institutions to facilitate extensive non-fiduciary operations.
The ICBA’s legal challenge takes direct aim at two regulatory instruments: the OCC’s March 2026 National Bank Chartering final rule and interpretive letter 1176, which was originally published in 2021. According to the ICBA, these policies allow entities participating in high-risk digital asset activities to access the national banking system under lighter supervisory demands than those imposed on traditional depository institutions. The association argues that this structure confers an unfair advantage to crypto-focused trust entities while creating public confusion, warning that end users could wrongly assume the term “national bank” indicates the presence of federal deposit insurance. The ICBA has asked the court to strike down both the 2021 letter and the March 2026 rule, thereby halting any further charter approvals based on them.
Data detailed within the ICBA lawsuit highlights the scale of this regulatory pathway: at least 21 trust banks have secured approval or conditional approval from the OCC, including a minimum of 13 cryptocurrency and blockchain firms. Responding to the litigation, the Crypto Council for Innovation criticized the trade group’s complaint on Monday, calling the lawsuit an attempt to stifle innovation as non-bank payment firms increasingly seek stable federal charters to cement their services.
Why This Matters
The contest over the OCC’s national trust charter framework highlights a critical pivot point for the modernization of American financial infrastructure. For companies like Rain and Modern Treasury, a national trust charter provides a direct regulatory pathway to unify custody, settlement, and stablecoin issuance across all 50 states without navigating an intricate patchwork of state-level money transmitter licenses. However, the ICBA’s legal challenge presents an immediate regulatory hurdle. If the court vacates the OCC’s interpretive guidance, pending applications could face significant delays or fundamental operational restructuring, determining how deeply digital-asset rails can integrate into the broader U.S. banking system.
Frequently Asked Questions
What would Rain National Trust Bank do if approved?
Rain National Trust Bank would operate as a federally regulated fiduciary, offering custody for digital assets and U.S. dollars to institutional clients, managing reserves for qualified stablecoin issuers, and facilitating the issuance and redemption of dollar-backed stablecoins under the $GENIUS Act.
Will Rain National Trust Bank offer traditional consumer banking services?
No. Rain plans to run the bank as a specialized subsidiary dedicated to digital-asset services and stablecoins. The entity will not accept consumer deposits, provide retail accounts, or issue corporate loans.
Why are community banks suing the OCC over crypto trust charters?
The Independent Community Bankers of America (ICBA) alleges that the OCC overstepped its legal authority by allowing non-depository trust banks to conduct extensive non-fiduciary crypto activities. The ICBA contends that this grants crypto firms the advantages of a national bank status without the strict compliance obligations placed on traditional community banks, potentially misleading customers regarding federal deposit insurance.
