Rain seeks U.S. trust bank amid crypto charter lawsuit

Oct 06, 2026

Rain has filed an application to create a U.S. national trust bank that could custody digital assets, manage stablecoin reserves, and issue dollar-backed stablecoins if the Office of the Comptroller of the Currency approves the plan.

Rain trust bank could hold reserves and issue stablecoins

If approved, Rain National Trust Bank would have three main business lines serving institutional clients, according to the company.

The bank would provide fiduciary custody for approved digital assets and U.S. dollars, with client property separated from its own assets. It could manage reserves for permitted stablecoin issuers and act as the issuer of record for U.S. dollar-backed stablecoins under the GENIUS Act.

OCC charter would not turn Rain into a regular bank

Despite the proposed bank name, Rain National Trust Bank would not operate like a traditional consumer bank.

Rain said the institution would not accept deposits, provide checking or savings accounts, offer consumer accounts or make commercial loans. It would operate as an uninsured national trust bank, meaning it would not carry FDIC deposit insurance.

Rain application comes as crypto charters face a court fight

Rain’s filing comes as community banks are challenging the OCC’s authority to approve national trust banks whose activities extend beyond traditional fiduciary services.

The Independent Community Bankers of America sued the OCC and Comptroller Jonathan Gould on Oct. 2 in the U.S. District Court for the District of Columbia. The case, Independent Community Bankers of America v. Office of the Comptroller of the Currency, was assigned case number 1:2026cv03441 to Judge Carl J. Nichols.

The complaint challenges a March 2026 OCC rule, Interpretive Letter 1176 and the conditional approval granted to Protego Holdings. ICBA argues that the agency has “far exceeded” its authority by allowing national trust banks to conduct non-fiduciary activities under a limited-purpose charter. The allegations have not been decided by the court.

ICBA wants the court to find the March rule and Interpretive Letter 1176 unlawful. Its complaint seeks to stop the OCC from relying on the disputed framework for additional approvals and asks the court to vacate Protego’s conditional charter approval.

Rain now faces OCC review and a public comment period

Rain’s application still requires OCC approval before the proposed bank can begin business.

The company said the review will include a public comment period, with the public portion of its application expected to appear on the OCC website. Rain has not provided a date for an OCC decision, and the regulator follows its own review timetable.

Rain worked with law firm Paul Hastings to prepare the application. Soto’s appointment as president and CEO remains subject to OCC review, while the proposed bank must receive all required regulatory approvals before starting operations.

The federal court challenge remains at an early stage. Public docket records show ICBA filed its complaint on Oct. 2, followed by attorney appearances and electronically issued summonses to the defendants and federal officials.

Rain said its national trust bank project is a multi-year initiative. Its existing card, wallet, and money-movement programs will remain in place while the OCC reviews the charter application, and the company said the proposed bank would begin operating only after receiving all required approvals.

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