Rain Applies for a National Trust Bank Charter as Community Banks Take the OCC to Court

Stablecoin payments infrastructure provider Rain has asked the Office of the Comptroller of the Currency for approval to open Rain National Trust Bank in New York. If approved, the bank could hold digital assets and US dollars in fiduciary custody for institutional clients and manage reserves for permitted stablecoin issuers. It could also issue and redeem dollar-backed stablecoins under the GENIUS Act. Brandon Soto, a former chief financial officer at Square Financial Services, is lined up as president and CEO, pending OCC review. Rain CEO and co-founder Farooq Malik said institutions building on the platform want their assets held by a fiduciary answerable to a federal regulator.

Crypto Firms Join the Trust Charter Queue

Rain is not alone. Modern Treasury, a payments infrastructure company, also filed on the same day for approval to offer digital asset custody and related fiat services. Over the past year, more crypto and payments companies have lined up for federal trust charters.

ICBA Lawsuit Against the OCC

The timing is awkward. On Friday, the Independent Community Bankers of America sued the OCC and Comptroller Jonathan Gould in the US District Court for the District of Columbia. The group says the agency overstepped by letting non-depository trust banks run broad non-fiduciary businesses.

It points to the OCC’s March 2026 chartering rule and its 2021 interpretive letter 1176, and argues they let risky crypto operations enter banking under lighter national charters. ICBA also warns consumers may assume “national bank” means federal insurance. It wants both overturned and further approvals blocked. The Crypto Council for Innovation called the suit an attempt to stifle innovation. According to the complaint, the OCC has approved or conditionally approved at least 21 trust banks, and at least 13 are crypto companies.