Rain Seeks U.S. Trust Bank Charter Amid OCC Crypto Lawsuit

Stablecoin payments provider Rain has applied to the Office of the Comptroller of the Currency to establish Rain National Trust Bank in New York. The filing adds to a series of applications from crypto and payments companies seeking national trust bank charters.

If approved, the bank would provide fiduciary custody of digital assets and U.S. dollars for institutional clients. It would manage reserves for permitted stablecoin issuers and issue and redeem dollar-backed stablecoins in accordance with the GENIUS Act.

Brandon Soto, former chief financial officer of Square Financial Services, would serve as president and CEO of the proposed bank, subject to OCC review. Rain CEO and co-founder Farooq Malik said in a statement that the company’s institutional clients wanted the assets supporting their programs held by a fiduciary supervised by a federal regulator.

Payments infrastructure company Modern Treasury also applied for a national trust bank charter on Monday. Its proposed bank would offer digital-asset custody and related fiat services.

Rain’s filing came days after the Independent Community Bankers of America sued the OCC and Comptroller Jonathan Gould in the U.S. District Court for the District of Columbia. The group alleges that the regulator exceeded its authority by allowing non-depository trust banks to conduct broad non-fiduciary activities.

The ICBA is challenging the OCC’s national bank chartering rule issued in March 2026 and Interpretive Letter 1176, issued in 2021. The group claims the framework allows crypto and digital-asset companies to enter the banking system through lightly regulated national trust charters instead of obtaining traditional bank charters with broader requirements.

The ICBA also alleges that crypto trust banks can offer services similar to those provided by community banks without facing the same obligations. The group claims consumers could mistake the “national bank” designation for confirmation that their assets have federal deposit insurance.

According to the ICBA’s complaint, the OCC has approved or conditionally approved at least 21 trust banks, including at least 13 crypto companies. The group is asking the court to overturn the 2026 rule and the 2021 interpretive letter and to block future charter approvals based on them.

The Crypto Council for Innovation criticized the lawsuit on Monday, describing it as an effort to restrict financial-services innovation. Rain’s proposed bank would focus on custody, reserve management and stablecoin services rather than conventional deposit-taking.