Rain, a stablecoin payments platform that issues cards, and Modern Treasury, a payments infrastructure company, said on Monday, October 5, 2026, that they had applied to the Office of the Comptroller of the Currency (OCC) for national trust bank charters. The announcements came three days after the Independent Community Bankers of America (ICBA) sued the OCC over how it grants that charter, particularly to crypto firms. They are the first applications submitted to the agency since the lawsuit, according to Banking Dive. Neither proposed bank would take deposits or make loans, and only Rain’s would issue stablecoins.
Rain wants to issue stablecoins and hold other issuers’ reserves
Rain National Trust Bank, headquartered in New York, would have three lines of business: fiduciary custody of digital assets and US dollars, reserve management for permitted stablecoin issuers under the GENIUS Act, and issuance and redemption of dollar-backed stablecoins as issuer of record. The assets behind the card, wallet, and money movement programs of Rain’s partners now sit across state licenses, third-party custodians, and third-party issuers. “The institutions building on Rain want the assets behind their programs held by a fiduciary that answers to a federal regulator,” said Farooq Malik, Rain’s CEO and co-founder.
The bank would not accept deposits, make commercial loans, or offer consumer accounts, and it would not be FDIC insured. Client assets would be custody assets, not liabilities of the bank, and the reserves backing any stablecoin it issues would not be pledged, lent, or reused. Rain would remain a Visa and Mastercard principal member through its other subsidiaries.
The proposed president and CEO, subject to OCC review, is Brandon Soto, most recently chief financial officer of Coastal Financial Corporation and earlier CFO of Square Financial Services, Block’s Utah-chartered industrial bank. “A trust bank’s first job is simple. Know what you hold, know who you hold it for, and keep it safe,” he said.
Modern Treasury adds custody but stays out of issuance
Modern Treasury, based in San Francisco, would run a limited-purpose national trust bank offering what it calls a unified custody solution. It would combine the company’s payments and settlement tools with digital asset custody so that customers can custody and move stablecoins and fiat in an integrated way. “Pursuing this charter will add direct federally supervised digital asset custody and related services to the infrastructure our customers already use,” said Matt Marcus, co-founder and CEO. The company has not yet named a proposed CEO for the bank, Banking Dive notes.
| Rain National Trust Bank | Modern Treasury National Trust Bank | |
|---|---|---|
| Custody | Digital assets and US dollars, as fiduciary | Stablecoins and fiat |
| Stablecoin issuance | Yes, as issuer of record | No |
| Reserves for other issuers | Yes, under the GENIUS Act | Not mentioned |
| Deposits and loans | No | No |
| Proposed CEO | Brandon Soto | Not yet named |
The lawsuit targets the OCC’s March 2026 trust charter rule
The ICBA filed suit on Friday, October 2, in the US District Court for the District of Columbia, under the Administrative Procedure Act. The case centers on the OCC’s March 2, 2026, final rule related to Interpretive Letter No. 1176 and asks the court to find both the rule and the letter unlawful. The group argues that the OCC’s statutory authority is limited to chartering trust banks that perform fiduciary activities, and that letting companies obtain the charter to conduct substantial non-fiduciary activities exceeds it. It also asks the court to vacate the charter the OCC conditionally approved in February 2026 for Protego Holdings, a digital asset firm.
Rebeca Romero Rainey, the ICBA’s president and CEO, said Congress did not create the national trust charter “as a side door into the banking system for crypto firms seeking the credibility of a federal bank charter without the Community Reinvestment Act obligations, consolidated supervision, capital and liquidity standards, and FDIC insurance that apply to insured depository institutions.”
OCC review and a public comment period come next
Both applications remain subject to OCC review and approval. Rain says the process includes a public comment period and that the public portion of its application will be posted on the OCC’s website. Modern Treasury says its bank will not open unless and until it receives the required regulatory approvals and final authorization from the OCC.