SKN | Rain Seeks US Trust Bank Charter as Crypto Banking Rules Face Court Challenge

Key Points

• Stablecoin payments infrastructure provider Rain has applied to the OCC to establish Rain National Trust Bank in New York.
• If approved, the proposed bank would provide institutional digital-asset and dollar custody, stablecoin reserve management, and stablecoin issuance and redemption services.
• Rain’s application comes days after the Independent Community Bankers of America sued the OCC over the legal framework used to grant national trust bank charters to crypto firms.

Stablecoin payments infrastructure provider Rain has applied for a national trust bank charter in the United States, entering a regulatory process that is simultaneously attracting crypto companies and facing a legal challenge from the country’s community banking sector.

Rain said it 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 proposed institution 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.

Brandon Soto, formerly chief financial officer of Square Financial Services, is expected to serve as president and CEO of the proposed bank, subject to OCC review.

Rain Targets Institutional Custody and Stablecoins

Rain’s proposed charter would give the company a federally regulated structure for expanding its institutional services.

The company said institutional customers want assets supporting their programs to be held by a fiduciary subject to federal regulatory oversight. Its proposed bank would therefore combine digital-asset custody with US dollar custody and stablecoin-related reserve services.

The application also reflects the expanding role of stablecoins within financial infrastructure. Rather than focusing solely on cryptocurrency trading, Rain is seeking authorization for activities connected to custody, payments and dollar-backed digital assets.

Rain is joining a growing group of crypto and payments companies pursuing national trust bank charters. The recent wave has included firms seeking to provide digital-asset custody and related financial services through federally chartered entities.

Community Banks Challenge OCC Framework

Rain’s application arrives only days after the Independent Community Bankers of America filed a lawsuit against the OCC in the US District Court for the District of Columbia.

The ICBA is challenging the OCC’s March 2026 national bank chartering rule and Interpretive Letter 1176, arguing that the agency exceeded its authority by allowing national trust banks to conduct substantial non-fiduciary activities.

The banking group argues that crypto trust banks can perform activities overlapping with traditional financial institutions while avoiding requirements that apply to insured depository banks, including deposit insurance, certain capital and liquidity standards, consolidated supervision and Community Reinvestment Act obligations.

ICBA also argues that consumers could misunderstand the meaning of a national trust charter and assume that assets held by such institutions carry the same federal protections associated with insured banks. Digital assets held by national trust banks are not federally insured simply because the institution has a national charter.

Trust Banks Differ From Traditional Banks

The dispute centers partly on the distinction between national trust banks and conventional full-service banks.

National trust banks generally do not accept deposits or make traditional loans. Their activities can instead include custody and other trust-related services, depending on the authority granted by the OCC. That structure means they do not operate under the same framework as insured depository institutions.

The ICBA is asking the court to overturn the OCC’s March 2026 rule and related 2021 interpretive guidance, as well as to prevent additional charter approvals that rely on the challenged framework.

According to the ICBA complaint, the OCC has approved or conditionally approved at least 21 national trust banks, including at least 13 crypto companies.

Legal Uncertainty Adds to Charter Race

The lawsuit introduces uncertainty for companies pursuing national trust charters at the same time that demand for regulated digital-asset infrastructure is expanding.

For firms such as Rain, a federal trust charter could provide a framework for offering institutional custody and stablecoin services while operating under direct federal supervision. However, the eventual outcome of the ICBA litigation could affect the regulatory foundation on which some of these charters are granted.

The OCC has continued approving or conditionally approving crypto-related trust bank structures. At the same time, the legal challenge means the boundaries of the agency’s authority over non-depository and non-fiduciary trust banks are now being tested in federal court.

Outlook

Rain’s application highlights the growing intersection between stablecoin infrastructure and the US banking system. The company is seeking a national trust structure at a time when crypto firms are increasingly pursuing federal charters to provide custody, payments and stablecoin-related services to institutional clients.

The immediate focus will be on the OCC’s review of Rain’s application and the broader court challenge brought by community banks. The legal proceedings could ultimately help define how far national trust bank charters can extend into digital-asset and other non-traditional financial activities.