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 entity would provide fiduciary custody of digital assets and US dollars for institutional clients, manage reserves for permitted stablecoin issuers, and issue dollar-backed stablecoins under the GENIUS Act. Former Square Financial Services CFO Brandon Soto is slated to serve as president and CEO, subject to regulatory review. Rain’s move coincides with a similar application from payments company Modern Treasury, reflecting a broader trend of crypto firms pursuing banking licenses.
The push for charters occurs against a backdrop of heightened legal tension. On Friday, the Independent Community Bankers of America (ICBA) sued the OCC and Comptroller Jonathan Gould 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 under lightly regulated national charters. The complaint specifically targets the OCC’s March 2026 chartering rule and a 2021 interpretive letter, arguing these frameworks allow crypto entities to compete with community banks without equivalent regulatory obligations or federal insurance protections. According to the ICBA, the OCC has approved or conditionally approved at least 21 trust banks, including at least 13 crypto companies.
Rain’s application underscores the strategic imperative for stablecoin infrastructure providers to secure federal oversight, aiming to reassure institutional clients that asset custody is managed by entities accountable to a primary regulator rather than private arrangements alone. By aligning with the GENIUS Act framework, Rain seeks to legitimize its role in reserve management and issuance, potentially lowering barriers to entry for traditional financial institutions hesitant to engage with unregulated crypto intermediaries. This development highlights how regulatory clarity, even when contested, drives corporate structuring decisions within the digital asset sector.
However, the concurrent ICBA lawsuit introduces significant operational and reputational risk to this wave of charter applications. The legal challenge directly questions the OCC’s authority to grant these licenses, suggesting that the current pathway for crypto firms may be legally fragile. If the court overturns the relevant rules, it could stall pending applications like Rain’s and force a reevaluation of how non-depository trust banks operate. Market participants must monitor whether the judiciary supports the OCC’s expansive interpretation of chartering powers or sides with community banks’ concerns about consumer protection and competitive fairness.
