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Policy

Rain Applies for Federal Trust Charter as Community Banks Challenge OCC Crypto Rules

TLDR Rain submitted an application to the OCC for Rain National Trust Bank, which would be headquartered in New York. The proposed institution would provide digital asset custody, oversee sta

AnonymousCryptoCompass newsroom
October 6, 2026
4 min read
NEWS
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TLDR

  • Rain submitted an application to the OCC for Rain National Trust Bank, which would be headquartered in New York.
  • The proposed institution would provide digital asset custody, oversee stablecoin reserves, and facilitate dollar-backed token issuance under GENIUS Act provisions.
  • The application arrives just three days after the Independent Community Bankers of America filed suit against the OCC regarding its crypto trust charter framework.
  • Brandon Soto, who served as CFO at Square Financial Services, has been designated as the prospective president and CEO.
  • Rain becomes the latest in a series of firms including Circle, Agora, and Zerohash pursuing federal trust charters.

Rain, a company focused on stablecoin payment infrastructure, has submitted a formal application for a national trust bank charter in the United States. The filing was lodged with the Office of the Comptroller of the Currency this past Monday.

Should regulators grant approval, the institution will be designated Rain National Trust Bank. The bank will maintain its headquarters in New York and function under OCC regulatory oversight.

Rain will maintain its current corporate structure. The trust bank will operate as an independently capitalized subsidiary entity rather than converting the parent company itself.

Services Planned for the Trust Bank

The institution plans to provide fiduciary custody services for both digital assets and US dollars targeting institutional customers. Additionally, it will oversee reserve management for licensed stablecoin providers.

The bank intends to facilitate the issuance and redemption of dollar-pegged stablecoins in accordance with requirements outlined in the GENIUS Act. Customer assets will remain segregated from the bank’s proprietary holdings.

According to Rain, the bank will not accept traditional deposits or provide retail banking products such as checking and savings accounts. Commercial lending will also be excluded from its service offerings.

Consequently, the institution will not qualify for FDIC deposit insurance coverage. Its operations will be limited to those of an uninsured national trust bank.

Farooq Malik, Rain’s CEO and co-founder, explained that clients utilizing Rain’s platform infrastructure seek to hold their assets with a fiduciary subject to federal regulatory supervision.

Brandon Soto has been designated for the roles of president and CEO. His background includes serving as CFO at Square Financial Services and subsequently at Coastal Financial Corporation. His appointment remains subject to OCC approval.

Rain’s application was submitted just three days following a lawsuit filed by the Independent Community Bankers of America against the OCC. The legal action was initiated on October 2 in the US District Court for the District of Columbia.

The organization contends that the OCC’s March 2026 chartering framework permits cryptocurrency firms to access the banking system under less stringent regulatory oversight than traditional banking institutions. The group further argues that consumers may mistakenly associate the designation “national bank” with federal deposit insurance safeguards.

The legal complaint names both the OCC and Comptroller Jonathan Gould as defendants. The plaintiffs are seeking judicial nullification of the rule along with a related 2021 interpretive letter.

The OCC maintained in February that the rule merely provided clarification of its pre-existing statutory authority. The regulator emphasized that the rule neither broadened nor restricted its chartering jurisdiction.

An OCC representative declined to provide comment on pending litigation.

Rain is among several entities pursuing this charter category. Circle secured final regulatory approval earlier this year for its institution, designated Circle National Trust.

Agora obtained conditional approval in September. Zerohash resubmitted a modified application in August following the return of an initial filing by regulatory authorities.

Based on assertions in the community bankers’ legal complaint, the OCC has granted full or conditional approval to no fewer than 21 trust banks. At least 13 of these institutions are cryptocurrency-focused companies.

Rain’s application will enter a public comment phase as part of the standard OCC evaluation protocol. The company has not disclosed an anticipated timeframe for a regulatory determination.

Rain indicated that its existing card, wallet, and money transfer operations will continue without interruption during the review period. The company characterized the trust bank initiative as a long-term undertaking that will commence only after securing complete regulatory clearance.

The post Rain Applies for Federal Trust Charter as Community Banks Challenge OCC Crypto Rules appeared first on Blockonomi.