Stablecoin payments company Rain has applied to the U.S. Office of the Comptroller of the Currency (OCC) for a national trust bank charter, becoming the latest crypto firm to seek federal oversight for custody and stablecoin reserve management.

The proposed New York-based subsidiary, Rain National Trust bank, would provide fiduciary custody of digital assets and U.S. dollars, manage reserves backing dollar-denominated tokens issued by permitted stablecoin issuers, and execute issuance and redemption for institutional clients, according to the application. The filing is subject to OCC approval and a public-comment period.

What would the trust bank actually do?

The proposed entity would not operate like a full-service commercial bank. Rain said the trust would not accept deposits, make commercial loans, offer consumer accounts or carry FDIC insurance, and client assets would be segregated from the bank's own holdings.

That narrow mandate defines the limited-purpose national trust bank model, which permits custody and fiduciary services without the deposit-taking and lending privileges that come with full bank charters. The structure is designed to bring stablecoin operations under direct federal supervision while shielding issuers from the balance-sheet requirements that apply to traditional lenders.

Who else is in the queue?

Rain joins a cohort that received initial OCC approval in December. Circle, Ripple, BitGo and Fidelity were among five crypto firms to clear that first regulatory hurdle, with Circle advancing to final OCC approval in late July for its own New York federal trust bank.

The clustering of applications reflects a broader rush for limited-purpose national trust-bank charters, as stablecoin issuers consolidate infrastructure under a single regulatory roof rather than relying on third-party banks to hold customer assets, administer reserves and handle issuance.

Why pursue a federal charter now?

National trust charters offer stablecoin issuers direct control over reserve administration, token minting and redemption, and custody of underlying collateral. For institutional clients, that translates to fewer intermediaries between dollar deposits and circulating tokens, and clearer legal accountability when reserves are lent, pledged or reused.

The charter route also gives crypto firms a defined federal supervisor rather than a patchwork of state-level oversight, a distinction that has grown more valuable as institutional stablecoin use expands.

What is the legal fight about?

Traditional lenders are contesting the OCC's authority to extend the charter at all. The Independent Community Bankers of America (ICBA) sued the OCC last week, arguing the agency lacks statutory power to grant national trust charters to crypto companies that do not provide core banking services. The ICBA said the structure gives crypto firms banking-style privileges without the same obligations FDIC-insured lenders face.

The complaint introduces a legal variable that could delay or constrain the OCC's approval pipeline, including Rain's application, depending on how a court rules on the agency's interpretation of its own chartering authority.

What happens next?

Rain's filing enters an OCC review process that combines standard supervisory examination with a public-comment window. The application will not become operational until the agency issues a formal decision, a timeline that has stretched from several months to more than a year for prior crypto trust applicants.

The litigation pending against the OCC adds uncertainty to that timeline. A ruling against the agency could force a restructuring of how limited-purpose trust banks serve digital-asset markets, while also shaping the parallel debate over federal stablecoin legislation working through Congress.