Rain seeks National Trust Bank license to issue stablecoins...

Stable coin payment infrastructure provider Rain applies to establish a federally chartered national trust bank

Stable coin payment infrastructure provider Rain has applied to New York to establish a federally chartered national trust bank. The move aims to bring digital asset custody, stablecoin reserve management and issuance of dollar-backed stablecoins under the direct supervision of the Office of the Comptroller of the Currency (OCC). If approved, Rain National Trust Bank will provide entrusted custody services for digital assets and US dollars to institutional customers, manage the reserves of approved stablecoin issuers, and issue and redeem dollar-backed stablecoins under the framework of the GENIUS Act.

The proposed institution will not take deposits, provide consumer accounts or issue commercial loans. Brandon Soto, former CFO of Square Financial Services, has been nominated as the proposed president and CEO, a appointment subject to OCC review. Rain itself will continue to operate as a payment platform, while the proposed trust bank will operate as an independently capitalized subsidiary.

Why did Rain seek a National Trust Bank license?

Rain's application aims to integrate functionality that currently relies on a combination of state licenses, external custodians and third-party stablecoin issuers. Integrating custody, reserve management and issuance functions into a federally regulated entity could provide institutional clients with a unified regulatory framework to support assets in their stablecoin payment plans. Rain CEO and co-founder Farooq Malik said the institutions that use the company's infrastructure want the assets behind it to be held by trustees under federal supervision.

This model is different from traditional commercial banks. Client assets will be held in a fiduciary capacity for specific owners rather than being treated as deposits; at the same time, reserves supporting the proposed bank-issued stablecoins cannot be pledged, borrowed or reused. Rain's move brings it to the rapidly expanding ranks as more digital asset and payment companies turn to OCC regulation. Previously FinanceFeeds reported that Block applied for its own National Trust Bank license in September to provide custody services for bitcoin, stablecoins and other digital assets.

Investor Revelation

For Rain, obtaining a license can reduce reliance on third-party financial infrastructure and integrate more stablecoin payment stack functions within the group. Its strategic value lies not in becoming a bank in the traditional sense, but in controlling custody, reserves and issuance under a single federal regulatory agency.

How crowded is the crypto-trust bank application pipeline?

Rain has entered a market where national trust licenses have become the digital asset industry's preferred route to enter federal banking supervision. Modern Treasury also announced on Monday that it has applied to the OCC for a limited purpose national trust bank license, focusing on digital asset custody and related fiat services. Unlike Rain's proposed institution, Modern Treasury said its banks would not issue stablecoins or issue loans. Other companies are making more progress. Bastion, a stablecoin infrastructure provider, received preliminary conditional approval from the OCC in September, and FinanceFeeds reported that its proposed bank would combine stablecoin custody, wallet, payment and white-label issuance services. Companies such as Coinbase, Ripple, Circle, BitGo, Fidelity Digital Assets and Paxos are also pursuing federal trust structures. FinanceFeeds reported in April that Coinbase received conditional approval from the OCC after filing in 2025.

Investor inspiration

The growing application pipeline shows that federal licensing is becoming an infrastructure strategy rather than an isolated compliance measure. For stablecoin companies, federal regulation can enhance institutional credibility while potentially simplifying operations that are otherwise scattered across multiple states and third-party arrangements.

Why is the OCC license path facing court challenges?

Rain提交申请之际，美国独立社区银行家协会（ICBA）已在联邦法院起诉OCC，直接挑战监管机构用于扩展加密货币公司国家信托牌照的法律基础。ICBA辩称，OCC允许非存款信托银行从事超出传统受托服务的大规模活动，同时规避适用于传统投保银行的监管要求，这超出了其权限。该组织要求法院撤销OCC 2026年3月的牌照规则和第1176号解释信，并阻止基于该框架的其他批准。根据起诉书，OCC已批准或有条件批准至少21家信托银行，其中包括至少13家加密货币公司。FinanceFeeds上周详细报道了ICBA对OCC提起诉讼的争议。行业方面的回应是，受联邦监管的信托实体为托管、结算和稳定币基础设施等活动提供了受监管的途径，而不必伪装成吸收存款的商业银行。如今，这一区别既是一个法律问题，也是一个竞争问题。

投资者启示

OCC审查只是Rain申请面临的众多风险之一。ICBA的诉讼可能会影响监管路径本身，因此投资者应密切关注单个牌照决定，以及法院是否维持OCC继续授予此类结构的权力。

Rain的未来走向如何？

Rain's application remains subject to OCC review, including a public comment process, and the proposed bank is not allowed to start operations until it receives regulatory approval and final authorization. However, the application demonstrates how the GENIUS Act is beginning to affect the structure of the stablecoin industry. Payment providers no longer rely solely on technology companies that connect external banks and custodians, but are increasingly considering federally regulated entities that can directly control custody, reserves, and issuance.

Whether this model will become a lasting part of the U.S. financial infrastructure now depends not only on the OCC's willingness to approve more applicants, but also on the court's interpretation of the extent of the National Trust Bank's powers.