Key facts
- Rain has applied to the OCC for a national trust bank charter in New York.
- The proposed Rain National Trust Bank would offer fiduciary custody of digital assets and US dollars for institutional clients.
- It would also provide reserve management for stablecoin issuers and issue/redeem dollar-backed stablecoins.
- Former Square Financial Services CFO Brandon Soto is slated to be president and CEO, pending OCC review.
- Payments infrastructure company Modern Treasury also announced a similar application on Monday.
- The Independent Community Bankers of America (ICBA) sued the OCC on Friday, challenging its rules for crypto trust charters.
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 in New York. The proposed bank would offer fiduciary custody of digital assets and U.S. dollars for institutional clients, manage reserves for stablecoin issuers, and handle the issuance and redemption of dollar-backed stablecoins.
Brandon Soto, former CFO of Square Financial Services, is expected to serve as president and CEO, subject to OCC approval. Rain CEO Farooq Malik stated that clients desire assets held by a federally regulated fiduciary.
Rain's application follows a trend of crypto and payments companies seeking national trust bank charters. Modern Treasury, another payments infrastructure company, also announced on Monday that it had submitted a similar application.
However, the move has faced opposition from community banks. On Friday, the Independent Community Bankers of America (ICBA) filed a lawsuit against the OCC and Comptroller Jonathan Gould. The ICBA alleges that the OCC exceeded its authority by allowing non-depository trust banks to engage in extensive non-fiduciary activities, particularly those involving risky cryptocurrency and digital assets.
The ICBA argues that the OCC's framework, including its National Bank Chartering final rule and interpretive letter 1176, grants crypto trust banks a competitive advantage by allowing them to offer services similar to community banks without facing the same stringent regulatory obligations. The group also expressed concern that the "national bank" designation might mislead consumers into believing their assets are federally insured.
The ICBA is seeking to overturn the OCC's March 2026 chartering rule and the 2021 interpretive letter, and to prevent future charter approvals based on these rules. The Crypto Council for Innovation, however, has criticized the lawsuit as an attempt to hinder innovation.
According to the ICBA's complaint, the OCC has approved or conditionally approved at least 21 trust banks, with at least 13 of them being crypto-focused companies.