Rain Wants a Trust Bank, Community Banks Want Rain to Wait — Cue Lawsuit at 11 🏦

Stablecoin payments infrastructure provider Rain has applied to establish a national trust bank headquartered in New York, joining a growing roster of crypto firms pursuing federal charters. Rain said Monday it filed the application with the Office of the Comptroller of the Currency (OCC) to form Rain National Trust Bank. If approved, the bank would offer fiduciary custody of digital assets and U.S. dollars to institutional clients, provide reserve management for permitted stablecoin issuers, and issue and redeem dollar-backed stablecoins in line with the GENIUS Act. Former Square Financial Services chief financial officer Brandon Soto is named as president and CEO of the proposed national trust bank, pending 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.

Payments infrastructure company Modern Treasury also announced Monday it had submitted an application seeking approval to offer digital asset custody and related fiat services. The pair add to a wave of crypto and payments firms that have sought national trust bank charters over the past year.

The OCC's chartering push, however, is now facing a court challenge. On Friday, the Independent Community Bankers of America sued the OCC in the U.S. District Court for the District of Columbia, naming the agency and Comptroller Jonathan Gould as defendants. The ICBA argued that the OCC's National Bank Chartering final rule and 2021's Interpretive Letter 1176 "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." The group said the framework gives crypto trust banks a competitive edge by letting them offer services that overlap with community banks without the same obligations, and warned consumers could mistake the "national bank" designation for federal deposit insurance.

The ICBA is asking the court to vacate the OCC's March 2026 chartering rule and the 2021 interpretive letter and to bar further charter approvals that rely on them. According to the complaint, the OCC has approved or conditionally approved at least 21 trust banks, of which at least 13 are crypto companies, including Bastion, which recently received conditional OCC approval. On Monday, the Crypto Council for Innovation characterized the lawsuit as an effort to stifle innovation. The OCC has not publicly commented on the litigation beyond acknowledging the filing.