Adding itself to a rising line of cryptocurrency companies pursuing federal trust charters is Rain, while a legal challenge filed by community banks asks a court to strike down the OCC regulations supporting those charters.
Submitting an application to set up a national trust bank based in New York, stablecoin payments infrastructure firm Rain joins a rising wave of digital asset enterprises seeking bank charters over the past year.
On Monday, an announcement from Rain confirmed the submission of its application to the Office of the Comptroller of the Currency (OCC) for founding Rain National Trust Bank. Approval of this charter would empower the institution to deliver fiduciary custody services for institutional clients handling digital assets and US dollars, manage reserves for authorized stablecoin issuers, and handle the issuance and redemption of dollar-pegged stablecoins under the guidelines of the GENIUS Act.
Pending regulatory review by the OCC, Brandon Soto—formerly the chief financial officer at Square Financial Services—will step into the role of president and chief executive officer for the proposed national trust bank.
“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.
Joining an expanding line of cryptocurrency and payment businesses pursuing national trust bank charters, Modern Treasury announced on Monday that it also submitted an application for regulatory approval to deliver digital asset custody and related fiat services.
Community Banks Raise Legal Challenge Against OCC Over Crypto Charters
However, this push has sparked backlash from community banks, leading the Independent Community Bankers of America to file a lawsuit against the OCC on Friday accusing the regulator of overstepping its bounds by granting non-depository trust banks permission to engage in extensive non-fiduciary operations.
Lodged within the US District Court for the District of Columbia, the legal complaint names both the OCC and Comptroller Jonathan Gould as defendants.
Criticism from the ICBA targeted the OCC’s National Bank Chartering final rule alongside a 2021 interpretive letter, arguing that these policies improperly enable businesses involved in volatile cryptocurrency and digital asset operations to infiltrate the banking system through lightly monitored national charters instead of forcing them through traditional, strictly regulated pathways.
The ICBA contended that this regulatory framework grants crypto trust banks an unfair competitive edge by enabling them to provide services overlapping with community banks while bypassing equivalent compliance burdens. Furthermore, the organization cautioned that ordinary consumers might misinterpret the “national bank” title as a federal guarantee insuring their deposited assets against loss.
In its legal filing, the association requested that the court invalidate the OCC’s March 2026 chartering guideline alongside the 2021 interpretive letter, while simultaneously seeking an injunction to block any future charter approvals based on those directives.
Characterizing the lawsuit as a transparent bid to stifle progress, representatives from the Crypto Council for Innovation issued a Monday statement condemning the legal challenge.
Outlining the figures in its complaint, the ICBA noted that the OCC has cleared or conditionally approved a minimum of 21 trust banks, with digital asset firms accounting for at least 13 of those entities.
