Rain Applies for OCC National Trust Bank Charter as 12th Crypto Firm

This application signifies a pivotal shift in the integration of cryptocurrency firms into the federal banking system.

• Rain filed an application with the OCC on October 5, 2026, to establish Rain National Trust Bank (RNTB) in New York.
• This makes Rain the 12th crypto firm seeking a national trust bank charter, aiming to provide fiduciary custody and stablecoin services.
• The application is pending review by the OCC and faces legal challenges from community banks concerned about regulatory oversight.

• Crypto firms are increasingly pursuing national trust bank charters to operate under federal supervision, allowing them to offer fiduciary services without traditional banking functions.
• The OCC has previously granted similar charters to firms like Circle and Ripple, indicating a trend towards regulatory acceptance of digital assets.
• Community banks are pushing back, arguing that these charters create an uneven playing field and threaten consumer protection.

Rain's application for a national trust bank charter is part of a broader trend where cryptocurrency firms seek to integrate into the traditional banking system. By applying for this charter, Rain aims to provide fiduciary custody of digital assets and U.S. dollars, manage reserves for stablecoin issuers, and issue U.S. dollar-backed stablecoins for institutional clients. This move is strategically designed to reduce reliance on third-party banks and custodians, which have historically been the gatekeepers of financial services.

The proposed Rain National Trust Bank (RNTB) will explicitly exclude deposit-taking, consumer accounts, and commercial lending, focusing solely on institutional services. This is a significant pivot for the crypto industry, which has often been viewed with skepticism by traditional financial institutions. The involvement of Brandon Soto, a seasoned executive with experience in financial services, as the proposed CEO, underscores Rain's commitment to operating within regulatory frameworks.

However, this application comes at a time of heightened scrutiny and legal challenges. The Independent Community Bankers of America (ICBA) has already filed a lawsuit against the OCC, arguing that the agency has overstepped its authority by allowing non-depository trust banks to engage in substantial non-fiduciary crypto activities without the same capital and liquidity requirements as traditional banks. This legal battle could set a precedent for how crypto firms are regulated in the future.

The push for national trust bank charters reflects a growing demand for federally supervised fiduciary services in the digital asset space. As institutional interest in cryptocurrencies and stablecoins continues to rise, firms like Rain are positioning themselves to meet this demand while navigating the complex regulatory landscape. The outcome of Rain's application and the ongoing legal challenges will likely influence the future of crypto banking and the broader acceptance of digital assets within the financial system.

• Institutional investors: They may gain access to more secure and regulated services for managing digital assets.
• Crypto firms: Other companies in the space will be watching closely to see how Rain's application impacts their own regulatory strategies.
• Community banks: They may face increased competition and regulatory challenges if more crypto firms gain charters.

• OCC's review timeline: The speed and outcome of the OCC's review will indicate how quickly crypto firms can integrate into the banking system.
• Legal developments from the ICBA lawsuit: The results of this legal challenge could reshape the regulatory landscape for crypto firms seeking similar charters.
• Market reactions to Rain's application: Observing how institutional clients respond to Rain's services could signal broader acceptance of crypto banking.