美国信任特许状制度转向信号：OCC加密诉讼后数日

Stable coin payment infrastructure provider Rain applies to establish National Trust Bank of New York

Stable coin payment infrastructure provider Rain has submitted an application to New York to establish a new National Trust Bank. The move will bring more stablecoins and digital asset services under the supervision of the Office of the Comptroller of the Currency (OCC). Rain's move further exacerbates a wave of growing trends in the cryptocurrency and payments industries seeking trust banking licenses over the past year.

Core Points

• Rain submitted an application to the Office of the Comptroller of the Currency (OCC) to establish a "Rain National Trust Bank", which aims to incorporate custody, reserve management and dollar-backed stablecoin functions into the federal trust structure.
• If approved, Rain's proposed bank would be authorized to provide fiduciary custody services for digital assets and U.S. fiat currencies to institutional customers, manage reserves for approved stablecoin issuers, and issue and redeem dollar-backed stablecoins under the GENIUS Act framework.
• Currently, many parties, including community banks, have filed legal challenges to the OCC's crypto-related concession granting method, and the bank's concession promotion process is facing resistance.
• Rain's proposed leadership includes Brandon Soto, who previously served as Chief Financial Officer of Square Financial Services, whose appointment is subject to OCC review and approval.
• Views within the industry are divided: supporters believe that licensing can help achieve regulated innovation; opponents warn that it could weaken the protection mechanisms associated with traditional banking licenses.

Rain seeks approval from the OCC Trust Bank, which focuses on stablecoin infrastructure.

Rain submitted an application to the OCC on Monday to establish the Rain National Trust Bank, which is headquartered in New York. Rain's stated business scope includes custody of digital assets and U.S. legal tender, management of reserves for approved stablecoin issuers, and issuance and redemption of dollar-backed stablecoins that comply with the GENIUS Act framework. This suggests the company's intention to move away from purely Infrastructure services to a regulated balance sheet business and a role close to custody services.

Rain also announced the leadership team of the proposed agency. Brandon Soto, former CFO of Square Financial Services, will serve as president and CEO after passing the OCC review process, the company said.

Rain CEO and co-founder Farooq Malik elaborated on the logic behind the move, emphasizing the value of faithful supervision. "Agencies building projects on top of Rain want the assets behind their projects to be held by a trustee who is accountable to federal regulators," he noted.

For investors and market participants, the practical significance is that trust bank licenses may change the way stablecoin-related custody and reserve arrangements operate. Instead of relying entirely on third-party custody or off-balance sheet arrangements, regulated trust banks can provide different compliance and governance postures-especially for those seeking to dispose of fiat and tokenized assets under federal supervision.

Broader wave of trust licenses: for custody and fiat settlement

Rain的申请并非孤例，其他加密货币和支付企业也在积极追求国家信托银行牌照。支付基础设施公司Modern Treasury于周一宣布，已提交申请以获取提供数字资产托管及相关法币服务的批准。

综合来看，这些申请凸显了一种趋势：稳定币生态系统和数字资产托管平台正越来越多地瞄准受监管的银行结构，以期以一种更符合传统金融利益相关者理解的方式支持法币处理和托管。尽管每个提案的最终边界取决于监管机构的批准，但这种模式表明，与稳定币相关的业务将信托牌照视为实现机构采用的途径。

社区银行通过诉讼抵制OCC的权限扩张

尽管与加密货币相关的企业正在追求信托银行牌照，但这一做法遭遇了强烈的反对。周五，独立社区银行家协会（ICBA）起诉了OCC，指控该监管机构越权，允许非存款类信托银行从事超出其认为信托牌照应涵盖范围的大量活动。

根据向美国哥伦比亚特区联邦地区法院提交的针对OCC和货币监理局局长Jonathan Gould的诉讼书，ICBA辩称，OCC的《国家银行特许最终规则》及2021年第1176号解释性信函“反常地允许从事高风险加密货币和数字资产活动的实体以轻度监管的国家牌照进入银行系统，而非受到更严格监管的传统银行牌照。”

The ICBA complaint highlights two major concerns. First, it claims that the licensing framework gives crypto trust banks a competitive advantage, allowing them to provide overlapping services with community banks, while avoiding the regulatory obligations that community agencies must assume. Second, the organization believes that consumers may mistakenly believe that the "national bank" label means assets are federally insured, even if this protection does not apply in the same way in traditional insured deposit banks.

In terms of remedies, ICBA requested the court to overturn the OCC's March 2026 concession rules and 2021 explanatory letter, and to block additional concession approvals based on these two provisions.

Proponents believe the lawsuit aims to curb regulated innovation

The lawsuit has also been criticized by cryptocurrency policy and advocacy groups. On Monday, the Crypto Council for Innovation said the lawsuit was an attempt to stifle innovation.

As part of the ICBA's argument, the complaint states that the OCC has approved or conditionally approved at least 21 trust banks, at least 13 of which are cryptocurrency companies. If the data in the complaint is directly accepted, this helps explain why community banks have characterized the issue as a systemic rather than an isolated incident: They believe that the pace and scale of trust license approvals are reshaping the competitive dynamics between community banks and licensed crypto-related institutions.

目前尚不确定的是，法院将如何评估OCC的特许权授予权限，以及任何裁决将如何影响待决申请、附条件批准或用于评估未来申请的监管标准。对于处于流程中的企业而言，这种法律不确定性不亚于监管时间表的影响。

展望未来，投资者和建设者应关注两条并行轨道：一是OCC对Rain申请的审查（以及可能附加的条件），二是质疑加密相关信托牌照基础的ICBA挑战的法律结果。这些发展将共同决定稳定币服务的受监管银行基础设施扩展的速度，以及这些路径在司法审查下的持久性。