Rain, a stablecoin payments platform, has filed for a national trust bank charter with the Office of the Comptroller of the Currency (OCC) on October 5, 2026. The move makes the company the twelfth crypto firm to apply for such a federal license, underscoring the accelerating integration of the digital asset sector into the US banking system.
🔑 Key takeaways
- Rain filed its national trust bank charter application with the OCC on October 5, 2026
- The company becomes the 12th crypto firm to seek such a federal license
- Rain National Trust Bank would be based in New York and operate as a separate, FDIC-uninsured subsidiary
- Three business lines: fiduciary custody, reserve management and stablecoin issuance under the GENIUS Act
- The OCC currently supervises roughly 60 national trust banks, the majority of which are uninsured
Rain becomes the twelfth crypto applicant at the OCC
Rain, a company focused on stablecoin payments, announced on October 5, 2026 that it had submitted its charter application to the OCC, the federal authority overseeing US national banks. The planned entity, named Rain National Trust Bank, would be based in New York and operate as a separate legal entity from the payments platform, which would itself remain non-bank.
With this move, Rain joins a growing queue of crypto firms seeking federal banking status. The company is relying on the OCC’s new rule published on March 2, 2026 in the Federal Register and effective April 1, 2026, which clarifies the long-standing authority of limited national trust banks to engage in non-fiduciary activities alongside their fiduciary business.
Three tightly defined business lines
Unlike a traditional commercial bank, Rain National Trust Bank would not accept deposits, offer checking or savings accounts, serve consumer customers or extend commercial loans. Its structure would be that of an uninsured national trust bank, with no FDIC coverage. Assets held in custody would remain identified as customer property and would not become liabilities of the bank. Reserves backing stablecoins issued by the proposed institution would not be pledged, lent or rehypothecated.
Three core activities are planned, all targeted at institutional clients:
- Fiduciary custody of approved digital assets and US dollars, with customer assets segregated from the bank’s own assets.
- Reserve management on behalf of duly authorized stablecoin issuers.
- Registered issuance of stablecoins backed by US dollars, under the federal GENIUS Act.
“Our institutional clients require that the assets supporting their programs be custodied by a trustee overseen by a federal regulator. The proposed bank is a separate entity that will hold client assets under OCC examination.”
Farooq Malik, CEO and co-founder of Rain
Governance, leadership and timeline
Rain has named Brandon Soto as the proposed president and chief executive officer of the future bank, subject to OCC approval. Soto brings solid traditional banking experience: he previously served as chief financial officer of Square Financial Services, the industrial bank chartered in Utah owned by Block, before becoming CFO at Coastal Financial Corporation.
The company worked with law firm Paul Hastings to prepare its application. The OCC review process will include a public comment period, with the public portion of the application to be posted on the regulator’s website. Rain has not provided any timeline estimate, as the OCC follows its own review schedule, and describes the project as “multi-year”. Throughout the review, Rain’s existing card, wallet and money transfer programs will remain operational. The bank will not begin operations until it has secured all required regulatory approvals, including final approval and authorization to open.
Legal clash with community bankers
Rain’s application comes amid a tense legal climate. The Independent Community Bankers of America (ICBA) filed a complaint on October 2, 2026, three days before Rain’s announcement, in the US District Court for the District of Columbia (case 1:2026cv03441, Judge Carl J. Nichols). The association is challenging the OCC’s March 2026 rule, interpretive letter 1176, and the conditional approval granted to Protego Holdings.
The ICBA accuses the OCC of having “far exceeded” its authority by allowing national trust banks to conduct non-fiduciary activities under a limited-purpose charter, arguing that these privileges are being granted to crypto firms without the obligations borne by traditional lenders.
The OCC sees things differently. The agency stated in its February bulletin announcing the rule that the change merely clarifies its long-standing authority, not an extension of its chartering power. Comptroller Jonathan Gould has publicly defended this approach, noting that the OCC evaluates whether applicants have a “reasonable chance of success” rather than applying a zero-risk standard. An OCC spokesperson declined to comment on Monday on the ongoing litigation.
A booming crypto trust charter market
As of December 31, 2025, total assets under administration reported by uninsured national trust banks supervised by the OCC reached $7 trillion, including $1.7 trillion in custody and safekeeping accounts and $5.3 trillion in fiduciary accounts. The OCC currently supervises about 60 national trust banks, the majority of which are uninsured.
| OCC status | Institution | Charter type |
|---|---|---|
| Final approval | First National Digital Currency Bank (Circle) | De novo |
| Conditional approval | Ripple National Trust Bank | De novo |
| Conditional approval | BitGo Bank & Trust, National Association | Conversion |
| Conditional approval | Fidelity Digital Assets, National Association | Conversion |
| Conditional approval | Paxos Trust Company, National Association | Conversion |
| Preliminary conditional approval | Coinbase National Trust Company | De novo |
| Preliminary conditional approval | Agora | De novo |
| Application under review | Rain, Zerohash | De novo |
On December 12, 2025, the OCC announced simultaneous conditional approval of five applications. In July 2026, Circle received final approval to operate its federal trust bank in New York under the name Circle National Trust. More recently, Agora received preliminary conditional approval in September after filing in April, while Zerohash submitted a revised application in August following the return of a prior filing.
OCC Corporate Decision No. 1370, published in April 2026, illustrates the rigor of the process: for Coinbase’s application to establish Coinbase National Trust Company in New York, the OCC granted preliminary conditional approval while waiving the residency requirement for four directors. The OCC had received five public comments: two from professional banking organizations and three from community groups, with four contesting the OCC’s authority to issue the charter. Final approval remains contingent on satisfying all pre-opening conditions.
Conclusion: between regulatory openness and banking resistance
Rain’s application reflects a broader trend: crypto infrastructure providers are now seeking an anchor in the federal banking system to reassure institutional clients and access custody and issuance services under prudential supervision. The OCC, under Comptroller Jonathan Gould, is pursuing a strategy of framed openness, while community banks are launching a legal offensive to slow this momentum.
The outcome of the ICBA lawsuit against the OCC will be a major test for the entire industry. If the March 2026 rule is struck down, several of the twelve current applications could see their trajectory disrupted. Conversely, an OCC victory would pave the way for a new wave of approvals, consolidating the integration of stablecoins and digital assets into the federal banking perimeter.
Sources
- CoinDesk
- Crypto.news
- OCC Corporate Decision 1370
- UC Berkeley Law – OCC Licensing Manual
- Federal Register – National Bank Chartering
- OCC News Release 2025-125
This article is published for informational and educational purposes only. It does not constitute investment advice. Do your own research (DYOR) before making any decision.
