Rain wants to open a federally regulated trust bank in New York to hold digital assets and issue US dollar-backed stablecoins under the GENIUS Act. The move comes as legal fights over crypto trust charters heat up.
Rain, a stablecoin payments company, has filed to set up a new federally regulated trust bank in New York. The bank would hold digital assets and manage reserves for stablecoin issuers. Rain has sent its application to the U.S. Office of the Comptroller of the Currency (OCC), asking for a national trust charter under the GENIUS Act. If the OCC signs off, Rain National Trust Bank could issue and redeem US dollar-backed stablecoins. It would not take deposits, open consumer accounts, or make commercial loans.
As of October 2026, Rain's application is still under review. The bank cannot start business until the OCC finishes its process, which includes a public comment period. The OCC plans to post the public part of Rain's application on its website. This is part of the agency's push for more transparency in chartering new banks.
Rain National Trust Bank is structured as a separately capitalized subsidiary, with Rain itself retaining its status as a payments infrastructure company while the bank will serve institutional clients.
Rain National Trust Bank will be a separate legal entity, fully capitalized and apart from its parent company. Rain will keep running as a payments infrastructure provider. The trust bank will focus only on institutional clients. This setup matches new regulatory trends, where digital asset custodians and stablecoin issuers are expected to keep their roles clearly separated.
Rain's plan has three main parts: holding approved digital assets and U.S. dollars for clients with strict separation, managing reserves for stablecoin issuers, and issuing stablecoins as a record-keeping entity under the GENIUS Act. The bank will not take deposits or make loans. Its main job will be secure custody and reserve management for institutional players in the digital asset space.
The rules for crypto trust banks are in flux. On October 2, 2026, the Independent Community Bankers of America (ICBA) sued the OCC and Comptroller Jonathan Gould in federal court. The ICBA is challenging the OCC's power to grant national trust charters to crypto firms that do not take deposits or do traditional fiduciary work. The lawsuit targets the OCC's March rule, Interpretive Letter 1176, and the conditional approval of the Protego charter. The ICBA says these steps go beyond what the law allows.
The GENIUS Act provides a legal framework for federally regulated entities to issue and redeem US dollar-backed stablecoins, but the operational requirements and legal status of such banks remain subject to ongoing litigation and regulatory review.
The ICBA's lawsuit claims that since the Trump administration, the OCC has approved or conditionally approved at least 21 national trust charters, with 13 tied to crypto companies. These numbers come from the ICBA and have not been confirmed by the court. The ICBA wants the OCC's March rule and Interpretive Letter 1176 thrown out, to stop them from being used in future charter approvals, and to cancel the conditional approval for Protego. The case is still in its early stages and does not directly affect Rain's pending application.
Stablecoin trust banks like Rain fill a specific role in the U.S. financial system. They do not take deposits or make loans. Instead, they focus on keeping digital assets safe and managing reserves for stablecoin issuers. This model is meant to handle the risks and rules that come with digital dollar products, but it also leaves these banks exposed to changing laws and court battles. As the rules keep shifting, whether trust banks can keep offering stablecoin services will depend on federal oversight and the results of ongoing lawsuits. For more on the regulatory debate, see the CoinDesk policy update.
