Rain Applies for US Trust Bank Charter to Issue Stablecoins Under GENIUS Act

Rain Files OCC Trust Bank Application

Stablecoin payments infrastructure provider Rain has applied to establish a national trust bank in the United States, filing with the Office of the Comptroller of the Currency (OCC) on Monday, 2026-10-05. The proposed entity, Rain National Trust Bank, would be headquartered in New York and, if approved, would hold digital assets and US dollars in fiduciary custody for institutional clients, manage reserves for permitted stablecoin issuers, and issue and redeem dollar-backed stablecoins under the GENIUS Act. Rain confirmed the step in its official announcement. Trust bank custody differs from self-custody, where an institution controls its own private keys and answers to no federal examiner. Rain builds stablecoin settlement rails for enterprise clients, including cards, wallets and transfers. Today it assembles custody and issuance through outside partners; a charter would consolidate those functions under direct federal oversight. The bank is planned as a separate subsidiary that will not accept deposits, offer consumer accounts or extend corporate loans, remaining focused on stablecoin and digital-asset services. Former Square Financial Services chief financial officer Brandon Soto is slated to serve as president and CEO, pending OCC review. Rain CEO and co-founder Farooq Malik said the institutions building on the platform want their program assets held by a fiduciary that “answers to a federal regulator.” The application joins a crowded field. Over the past year, crypto and payments companies have pushed for national trust charters, and payments infrastructure firm Modern Treasury said on the same Monday it had filed for approval to offer digital asset custody and related fiat services. Rain's application now enters OCC review; operations would begin only after the required approvals.

Community Banks Sue Over Crypto Charters

The filing arrives against a widening legal fight. On Friday, 2026-10-02, the Independent Community Bankers of America (ICBA) sued the OCC and Comptroller Jonathan Gould in the US District Court for the District of Columbia, arguing the regulator exceeded its authority by letting non-depository trust banks conduct extensive non-fiduciary activities. The complaint targets two instruments together: the OCC's National Bank Chartering final rule from March 2026 and interpretive letter 1176, issued in 2021. In the ICBA's reading, those instruments let firms engaged in high-risk cryptocurrency and digital-asset activity enter the banking system through lightly regulated national charters, while traditional bank charters carry far stricter requirements. The group also contends the setup hands crypto trust banks a competitive edge, since their services overlap with community banks that face heavier obligations, and that consumers may mistake the “national bank” designation for a promise of federal deposit insurance. It asked the court to vacate the March 2026 rule and the 2021 letter and to block further approvals resting on them. The complaint's own tally shows how large the program has grown: at least 21 trust banks approved or conditionally approved, with at least 13 of them crypto companies. The Crypto Council for Innovation pushed back on Monday, calling the lawsuit an attempt to stifle innovation. The pipeline now extends past crypto-native firms, and fear of missing out on a federal charter is visibly reshaping how payments companies structure custody and issuance.

OCC Review Decides the Next Phase

The two Monday applications and Friday's lawsuit bracket one question: how fast crypto merges into the federal banking system. The framework is no longer a proposal. The GENIUS Act, enacted in 2025, set up federal supervision for stablecoin issuers, and the OCC spent 2026 drafting rules on issuance, reserve assets and reporting that give the statute force. Rain's charter would bind it to reserve and redemption duties under OCC examination while forgoing deposits and lending, a very different discipline from trading desks running perpetual futures or crypto options, where implied volatility reprices by the minute. Since the March 2026 rule under challenge is final, not proposed, both applications can proceed through litigation; the DC ruling will set their pace.