Modern Treasury and Rain have applied to the OCC.
Modern Treasury and Rain have officially submitted their applications to the Office of the Comptroller of the Currency (OCC) in order to be approved for the national trust bank charter licenses.
This makes both companies the latest round of fintechs looking to establish a separate stablecoin subsidiary to manage and custody stablecoins as required under the Genius Act.
Recently, OCC approved featuring Agora, Bastion, and Catena.
Stablecoins – An Evolving Thesis
Stablecoin companies such as Rain have seen a tremendous rise over the last 18 months.
Rain in particular went through several rounds of funding in a short space of time, including acquisitions of several digital asset companies for security, rewards, and wallet infrastructure.
Rain also leads the stablecoin card program issuance to date as shown by PaymentScan metrics.
Recently, MoneyGram launched its stablecoin card based on Rain’s infrastructure and Rain’s support for the KRW stablecoin went live to scale adoption of local currency stablecoins.
For Modern Treasury, the payment, treasury, and payroll functionality continues to evolve even after its acquisition of Beam to integrate stablecoin rails into traditional transfers.
As enterprise clients demand 24/7 payment sending and acceptance functionality, stablecoins have allowed Modern Treasury to serve a product growing among large corporates.
The objective of an OCC charter license allows both companies to ensure even more of the payment flows and custody is managed by their own operations and reducing third-parties.
Approvals Before Time Runs Out?
The OCC has spent 2025 and 2026 approving new types of banks.
These are not the traditional deposit-taking banking charter institutions with a prime focus on lending to local businesses, farmers, and consumers for personal and mortgage products.
Rather, the OCC has been approving a new wave of fintechs and firms intending to operate with stablecoins and other digital assets under its direct federal supervision.
As per the Genius Act, any entity wishing to engage with payment stablecoins, whether that’s issuance, custody, staking, or conduct white-label services, is required to establish a newly licensed subsidiary supervised by the OCC and limited in-purpose.
OCC has already released its own rulemaking proposals for regulating payment stablecoins. This type of a national trust bank has its own identified scope of what it can and cannot do.
It also ensures a separate collateral and underlying capital requirements to the entity or banking institutions’s main balance sheet, with 1:1 backing required for stablecoin reserves.
For banks looking to issue stablecoins this will be an uncomfortable change, while newer fintechs already issuing or custodying stablecoins under these practices may adapt more easily.
In the U.S., there is a foundational shift happening in banking.
Recently, the Independent Community Bankers of America (ICBA) filed a lawsuit against the OCC’s approvals of such firms.
Many regional and community banks find themselves on the other side of large investment and international banks adopting stablecoins and tokenized deposits.
