Rain Files for US Trust Bank Charter as Community Banks Sue OCC Over Crypto Rules

Stablecoin payments infrastructure provider Rain has filed an application with the Office of the Comptroller of the Currency (OCC) to establish Rain National Trust Bank, headquartered in New York. If approved, the bank would provide fiduciary custody of digital assets and dollars for institutional clients, offer reserve management for permitted stablecoin issuers, and issue and redeem dollar-backed stablecoins in compliance with the GENIUS Act. Former Square Financial Services CFO Brandon Soto is set to serve as president and CEO, pending OCC review. "The institutions building on Rain want the assets behind their programs held by a fiduciary that answers to a federal regulator," said Rain CEO and co-founder Farooq Malik.

Rain's application comes just days after the Independent Community Bankers of America (ICBA) filed a lawsuit against Comptroller Jonathan Gould and the OCC in the US District Court for the District of Columbia. The ICBA alleges the regulator exceeded its authority by permitting non-depository trust banks to conduct extensive non-fiduciary activities through the OCC's National Bank Chartering final rule and 2021's Interpretive Letter 1176. The group contends the framework gives these lightly regulated entities a competitive edge over traditional, more rigorously regulated community banks while potentially misleading consumers about federal deposit insurance.

Rain is part of a growing wave of crypto and payments firms pursuing national trust bank charters. Payments infrastructure company Modern Treasury also announced Monday that it submitted its own application for digital asset custody and related fiat services. Earlier, Bastion secured conditional OCC approval for a national trust bank charter. The surge in applications underscores crypto firms' push for federal legitimacy and direct access to banking infrastructure, even amid heightened legal scrutiny.

The ICBA has asked the court to overturn the OCC's March 2026 chartering rule and the 2021 interpretive letter, setting up a pivotal legal battle that could reshape how crypto companies access the US banking system. The outcome will likely influence whether the current pipeline of trust charter applications, including Rain's, can move ahead under existing regulatory pathways.