Rain Files for US National Trust Bank Charter as Community Banks Challenge OCC
Key Takeaways
- •Rain has filed an application with the Office of the Comptroller of the Currency to establish Rain National Trust Bank, headquartered in New York.
- •If approved, the bank would provide fiduciary custody of digital assets and US dollars for institutional clients, reserve management for permitted stablecoin issuers, and issue and redeem dollar-backed stablecoins under the GENIUS Act.
- •Brandon Soto, formerly chief financial officer of Square Financial Services, will serve as president and CEO of the proposed bank, subject to OCC review.
- •Payments infrastructure firm Modern Treasury separately announced on the same day that it applied to offer digital asset custody and related fiat services.
- •The Independent Community Bankers of America has sued the OCC in federal court, seeking to overturn its chartering rule and 2021 interpretive letter on the grounds that crypto trust banks gain an unfair competitive advantage without equivalent regulatory obligations.

Stablecoin payments infrastructure provider Rain has applied to establish a national trust bank headquartered in New York, joining a growing wave of crypto companies seeking bank charters over the past year.
Rain said Monday that it filed the application with the Office of the Comptroller of the Currency (OCC) to establish Rain National Trust Bank. If approved, the institution would be authorized to provide fiduciary custody of digital assets and US dollars for institutional clients, offer reserve management for permitted stablecoin issuers, and issue and redeem dollar-backed stablecoins in accordance with the GENIUS Act, the federal statute governing stablecoins.
Brandon Soto, formerly chief financial officer of Square Financial Services, will serve as president and CEO of the proposed national trust bank, subject to OCC review.
“The institutions building on Rain want the assets behind their programs held by a fiduciary that answers to a federal regulator,” Rain CEO and co-founder Farooq Malik said.
Rain is among a growing number of crypto and payments companies pursuing national trust bank charters. Payments infrastructure firm Modern Treasury also announced Monday that it had submitted an application seeking approval to offer digital asset custody and related fiat services. The applications land at a sensitive moment for the chartering pathway itself, which is now facing a legal challenge from the traditional banking industry.
Community banks challenge OCC over crypto trust charters
On Friday, the Independent Community Bankers of America (ICBA) sued the OCC, alleging that the regulator exceeded its authority by allowing non-depository trust banks to conduct extensive non-fiduciary activities.
The lawsuit was filed in the US District Court for the District of Columbia against the OCC and Comptroller Jonathan Gould.
The ICBA argued that the OCC’s National Bank Chartering final rule and interpretive letter 1176 from 2021 “perversely allow entities engaged in highly risky cryptocurrency and digital assets activities to enter the banking system under lightly regulated national charters rather than the more rigorously regulated traditional bank charter.”
According to the ICBA, the framework gives crypto trust banks a competitive advantage by allowing them to offer services that overlap with those of community banks without facing the same regulatory obligations. The group also alleged that consumers could mistake the “national bank” designation as assurance that their assets are federally insured.
The ICBA has asked the court to overturn the OCC’s March 2026 chartering rule and the 2021 interpretive letter, and to block further charter approvals that rely on them. How the court rules could determine whether further charter approvals proceed under the current framework.
On Monday, the Crypto Council for Innovation said the lawsuit was an attempt to stifle innovation.
According to the ICBA’s complaint, the OCC has approved or conditionally approved at least 21 trust banks, with at least 13 of them being crypto companies. For applicants like Rain and Modern Treasury, the next step is OCC review, even as the court weighs a challenge to the framework that underpins such charters.