Stablecoin payments infrastructure provider Rain has submitted an application to the Office of the Comptroller of the Currency to establish a national trust bank based in New York. The proposed institution, Rain National Trust Bank, would focus on fiduciary custody of digital assets and U.S. dollars for institutional clients, reserve management for permitted stablecoin issuers, and the issuance and redemption of dollar-backed stablecoins consistent with the GENIUS Act.

Rain would continue operating its existing payments platform as a separate entity. The bank itself would function as a separately capitalized subsidiary under OCC supervision and would not accept deposits, offer consumer checking or savings accounts, or extend commercial loans. Client assets would remain segregated from the bank’s own holdings, and any stablecoin reserves would not be pledged, lent, or reused. The institution would operate as an uninsured national trust bank without FDIC coverage.

Proposed Leadership and Business Scope

Former Square Financial Services chief financial officer Brandon Soto has been named as the proposed president and chief executive of the new bank, subject to OCC review. Soto later served as chief financial officer at Coastal Financial Corporation. Rain prepared the application with support from the law firm Paul Hastings.

Company executives stated that partners currently rely on a mix of state licenses, external custodians, and third-party stablecoin issuers to support card, wallet, and money-transfer programs serving millions of end users. The trust bank application seeks to consolidate certain of those functions under a single federally supervised entity.

The filing remains subject to a full OCC review process that includes a public comment period. Rain described the project as a multi-year initiative and said existing services will continue while the application is under consideration.

Application Arrives Amid Legal Challenge to OCC Authority

Rain’s submission follows by only a few days a lawsuit filed by the Independent Community Bankers of America against the OCC and Comptroller Jonathan Gould. The complaint, lodged on October 2 in the U.S. District Court for the District of Columbia, challenges the agency’s March 2026 National Bank Chartering final rule and Interpretive Letter 1176 from 2021.

The community banking group contends that the OCC exceeded its statutory authority by permitting non-depository trust banks to engage in extensive non-fiduciary activities, particularly those involving cryptocurrency and digital assets. According to the complaint, the framework allows such entities to enter the banking system under lighter regulation than traditional charters while competing with community banks that face stricter capital, liquidity, and supervisory requirements. The group also raised concerns that the “national bank” label could lead consumers to assume federal deposit insurance protection that does not apply to uninsured trust banks.

ICBA asked the court to set aside the disputed rule and interpretive letter, block additional charter approvals that rely on them, and vacate certain conditional approvals already granted. The complaint states that the OCC has approved or conditionally approved at least 21 trust banks, of which at least 13 are crypto-related companies.

The OCC has maintained that its rule merely clarifies longstanding authority to allow national trust banks to conduct non-fiduciary activities alongside fiduciary ones and does not expand or contract the agency’s powers. The regulator has declined to comment on the pending litigation.

Broader Wave of Crypto and Payments Charter Applications

Rain’s application adds to a series of filings by digital-asset and payments firms seeking national trust bank status. Payments infrastructure company Modern Treasury announced on the same day that it had also submitted an application for digital asset custody and related fiat services. Circle previously received final OCC approval for First National Digital Currency Bank, operating as Circle National Trust, which began with fiduciary digital asset custody. Other applicants, including Agora and Zerohash, remain at various stages of the process, with some having received preliminary or conditional approvals.

Crypto industry advocates have characterized the ICBA lawsuit as an effort to limit innovation in the sector. The court case is still in its early stages, with the complaint filed and summonses issued. Rain’s application will proceed under the existing regulatory framework unless a court intervenes.

The outcome of both the individual charter reviews and the broader legal challenge will shape how crypto and stablecoin infrastructure providers can obtain federal banking oversight for custody, reserve, and issuance functions in the coming years.