Rain seeks US trust bank charter amid OCC challenge

Stablecoin payments infrastructure provider Rain has applied to the OCC to establish Rain National Trust Bank, a New York-headquartered fiduciary institution. The application, led by proposed CEO Brandon Soto, arrives amid intense legal friction. Just days earlier, the Independent Community Bankers of America sued the OCC, claiming the regulator exceeded its authority by allowing crypto firms to secure limited-purpose national charters. While Rain seeks to manage stablecoin reserves and custody digital assets, community banks argue the framework creates an unfair, lightly regulated backdoor into the federal banking system.

Proposed operations of Rain National trust bank

• ▪If approved, Rain National Trust Bank would provide fiduciary custody of digital assets and U.S. dollars, manage reserves for permitted stablecoin issuers, and issue and redeem dollar-backed stablecoins under the GENIUS Act
• ▪Rain National Trust Bank would not accept deposits, offer consumer checking or savings accounts, or make commercial loans, meaning it would not carry Federal Deposit Insurance Corporation deposit insurance
• ▪Rain's proposed Rain National Trust Bank would be headquartered in New York and operate as a separately capitalized, uninsured subsidiary under Office of the Comptroller of the Currency supervision
• ▪Stablecoin payments infrastructure provider Rain filed an application with the Office of the Comptroller of the Currency on October 5, 2026, to establish Rain National Trust Bank

Brandon Soto's executive background

• ▪Rain named Brandon Soto, the former chief financial officer of Square Financial Services, as the proposed president and CEO of Rain National Trust Bank, subject to regulatory review
• ▪Brandon Soto, the proposed president and CEO of Rain National Trust Bank, previously served as the chief financial officer of Coastal Financial Corporation

The ICBA lawsuit against the OCC

• ▪The Independent Community Bankers of America's Oct. 2 lawsuit alleges that the Office of the Comptroller of the Currency has approved or conditionally approved at least 21 trust banks, with at least 13 being crypto companies
• ▪The Independent Community Bankers of America lawsuit challenges a March 2026 Office of the Comptroller of the Currency rule, Interpretive Letter 1176, and the conditional charter approval granted to Protego Holdings
• ▪The Independent Community Bankers of America filed a federal lawsuit against the Office of the Comptroller of the Currency and Comptroller Jonathan Gould on October 2, 2026, in the U.S. District Court for the District of Columbia
• ▪The Independent Community Bankers of America argues that the Office of the Comptroller of the Currency exceeded its authority by allowing national trust banks to conduct non-fiduciary activities under limited-purpose charters

OCC regulatory standards

• ▪Comptroller Jonathan Gould defended the Office of the Comptroller of the Currency's approach to trust bank applications, stating the agency assesses whether applicants have a reasonable chance of success instead of applying a zero-risk standard
• ▪The Office of the Comptroller of the Currency stated that its April 1, 2026, charter rule merely clarified its longstanding authority to let national trust banks conduct non-fiduciary activities and did not expand its powers

Other crypto trust bank applicants

• ▪Payments infrastructure company Modern Treasury also submitted an application on October 5, 2026, seeking Office of the Comptroller of the Currency approval to offer digital asset custody and related fiat services
• ▪Other crypto-focused national trust bank applicants besides Rain include Circle, which received final approval for Circle National Trust in July 2026, alongside Agora and Zerohash, which remain at different stages of the national trust bank charter application process

Debatable claims

• ▪The 'national bank' designation for uninsured trust banks risks misleading consumers about federal deposit insurance
• ▪The OCC's crypto trust charters create an unfair competitive disadvantage for traditional banks
• ▪The OCC exceeds its legal authority by granting national trust bank charters for non-fiduciary activities
• ▪A national trust bank charter provides cryptocurrency companies with a recognized federal regulatory framework that helps navigate varying state regulations and offers institutional clients the comfort of federally supervised oversight