Rain files for a stablecoin trust bank three days after community bankers sued to stop new charters

"The institutions building on Rain want the assets behind their programs held by a fiduciary that answers to a federal regulator," Farooq Malik, Rain's chief executive and co-founder, said ^[11]. If the OCC agrees, one Rain subsidiary would provide custody for institutional clients and manage reserves for permitted stablecoin issuers. It would also issue and redeem dollar stablecoins under the GENIUS Act ^[1]. The announcement, as reported, does not include the subsidiary's capital or its pricing.

The suit goes after future charters as well as the rules behind past ones. The ICBA asks the court to overturn the OCC's chartering rule and a 2021 interpretive letter, and to stop further approvals that rely on them ^[13]. A pending filing like Rain's is exactly what that second request would hold up ^[4]. The complaint says the rule and letter "perversely allow entities engaged in highly risky cryptocurrency and digital assets activities to enter the banking system under lightly regulated national charters rather than the more rigorously regulated traditional bank charter" ^[8]. According to crypto.news, the OCC says its rule clarified existing authority and did not expand powers ^[14]. That outlet dates the rule to April, while Cointelegraph's account of the complaint calls it the March 2026 rule ^[14][13].

The complaint counts at least 21 trust banks the OCC has approved or conditionally approved, and at least 13 of them are crypto companies ^[15]. Taking those minimums, crypto firms hold about 62% of the approvals ^[18]. Agora filed in April and won preliminary conditional approval in September ^[17], about five months later ^[19].

A bar on further approvals would leave Rain's application waiting on the litigation. If the court accepts the OCC's reading, Rain is on something like Agora's five-month clock. The slower outcome is a suit that runs long while the OCC keeps approving, so any ruling against the regulator arrives later and reaches more than 13 crypto banks ^[15].

I think Rain's design answers the consumer half of the ICBA's case and leaves the legal half standing. The bankers argue that customers could mistake a "national bank" name for federal deposit insurance ^[9]. Rain's bank would be uninsured. But it would serve institutional clients and offer no checking, savings or consumer accounts ^[1][2]. The authority claim, that the OCC overstepped by letting non-depository trust banks run extensive non-fiduciary activities ^[12], does not depend on who the customers are. Issuing stablecoins and managing other issuers' reserves are the Rain lines furthest from traditional fiduciary work, so I'd expect that claim to reach them first. The OCC's counter is that if the rule only clarified existing authority, Rain is asking for powers trust banks already had ^[14].

The case for the charter rests on a Rain-owned entity issuing tokens and holding the reserves behind them. It fails if approval comes in stages. Circle's trust bank received final OCC approval in July and was reported to begin with fiduciary digital asset custody, with the option to serve selected institutional clients later ^[10]. An approval on those terms would leave Rain's reserve and issuance lines on hold whichever way the court rules.