By Stablecoin payments infrastructure provider Rain has applied to establish a federally chartered national trust bank in New York, seeking to bring digital asset custody, stablecoin reserve management and dollar-backed stablecoin issuance under direct supervision of the Office of the Comptroller of the Currency.
If approved, Rain National Trust Bank would provide fiduciary custody of digital assets and US dollars for institutional clients, manage reserves for permitted stablecoin issuers and issue and redeem dollar-backed stablecoins under the GENIUS Act framework. The proposed institution would not accept deposits, offer consumer accounts or make commercial loans.
Former Square Financial Services CFO Brandon Soto has been named proposed president and CEO, subject to OCC review. Rain itself would remain a payments platform, while the proposed trust bank would operate as a separately capitalized subsidiary.
Why Does Rain Want a National Trust Bank?
Rain’s application is aimed at consolidating functions that currently rely on a combination of state licenses, external custodians and third-party stablecoin issuers. Bringing custody, reserve management and issuance into a federally supervised entity could give institutional clients a single regulatory framework for the assets supporting their stablecoin payment programs.
Rain CEO and co-founder Farooq Malik said institutions using the company’s infrastructure want the assets behind their programs held by a fiduciary subject to federal supervision.
The model differs from a traditional commercial bank. Client assets would be held in custody for identified owners rather than treated as deposits, while reserves supporting stablecoins issued by the proposed bank would not be pledged, lent or reused.
The application adds Rain to a rapidly expanding group of digital asset and payments companies moving toward OCC supervision. FinanceFeeds previously reported that Block applied for its own national trust bank charter in September to provide Bitcoin, stablecoin and other digital asset custody services.
Investor Takeaway
For Rain, a charter could reduce reliance on third-party financial infrastructure and move more of the stablecoin payment stack inside the group. The strategic value lies less in becoming a conventional bank than in controlling custody, reserves and issuance under one federal supervisor.
How Crowded Is the Crypto Trust Bank Pipeline?
Rain is entering a market in which national trust charters have become one of the digital asset industry’s preferred routes into federal banking supervision.
Modern Treasury also announced an OCC application on Monday for a limited-purpose national trust bank focused on digital asset custody and related fiat services. Unlike Rain’s proposed institution, Modern Treasury said its bank would not issue stablecoins or make loans.
Other companies are further along. Stablecoin infrastructure provider Bastion received preliminary conditional OCC approval in September, with FinanceFeeds reporting that its proposed bank would combine stablecoin custody, wallets, payments and white-label issuance.
Coinbase, Ripple, Circle, BitGo, Fidelity Digital Assets and Paxos have also pursued federal trust structures. FinanceFeeds reported in April that Coinbase received conditional OCC approval after applying in 2025.
Investor Takeaway
The growing application pipeline suggests federal chartering is becoming an infrastructure strategy rather than an isolated compliance exercise. For stablecoin companies, federal supervision can support institutional credibility while potentially simplifying businesses otherwise spread across multiple state and third-party arrangements.
Why Is the OCC Charter Route Now Facing a Court Challenge?
Rain’s filing comes just days after the Independent Community Bankers of America sued the OCC in federal court, directly challenging the legal foundation the regulator has used to expand national trust charters for crypto companies.
The ICBA argues that the OCC exceeded its authority by allowing non-depository trust banks to conduct substantial activities outside traditional fiduciary services while avoiding requirements that apply to conventional insured banks. The group is asking the court to invalidate the OCC’s March 2026 chartering rule and Interpretive Letter 1176 and prevent additional approvals relying on that framework.
According to the complaint, the OCC has approved or conditionally approved at least 21 trust banks, including at least 13 crypto companies. FinanceFeeds detailed the dispute when the ICBA filed its lawsuit against the OCC last week.
The industry’s response has been that federally supervised trust entities provide a regulated route for activities such as custody, settlement and stablecoin infrastructure without pretending to be deposit-taking commercial banks. That distinction is now becoming a legal question as well as a competitive one.
Investor Takeaway
The OCC review is only one risk facing Rain’s application. The ICBA litigation could affect the regulatory pathway itself, meaning investors should watch both individual charter decisions and whether courts uphold the OCC’s authority to continue granting these structures.
What Happens Next for Rain?
Rain’s application remains subject to OCC review, including a public-comment process, and the proposed bank cannot begin operating without regulatory approval and final authorization.
The application nevertheless illustrates how the GENIUS Act is beginning to influence the structure of the stablecoin industry. Rather than relying solely on technology companies connected to external banks and custodians, payment providers are increasingly considering federally supervised entities that can directly control custody, reserves and issuance.
Whether that model becomes a durable part of US financial infrastructure may now depend not only on the OCC’s willingness to approve additional applicants, but also on the courts’ interpretation of how far national trust bank powers can extend.