Modern Treasury applied to the OCC on October 5, 2026 to establish Modern Treasury National Trust Bank, a limited-purpose national trust bank, the company announced. The proposed bank would custody stablecoins and fiat alongside Modern Treasury’s payments platform. It would not make loans or issue stablecoins, and it cannot open without OCC approval and final authorization.
What Modern Treasury filed
The application asks the Office of the Comptroller of the Currency to charter a bank that would “operate as a federally regulated, limited-purpose national trust bank under OCC supervision”, per the release. The bank would give customers “a unified custody solution” that joins Modern Treasury’s payments and settlement with digital asset custody, so they can “custody and move stablecoins and fiat” in one place.
The trust bank would be a separate entity offering “only the services authorized by the OCC”. Modern Treasury’s software and its payment service provider business continue as before, and the company says “nothing changes for its customers, bank partners, or stablecoin partners.”
“We have now fully integrated stablecoins to our payments platform,” said Matt Marcus, co-founder and CEO. “Pursuing this charter will add direct federally supervised digital asset custody and related services to the infrastructure our customers already use.”
Modern Treasury is best known for payment operations software and its double-entry ledger API, profiled in modern treasury ledgers. The release says it has powered over $600 billion in payments and is backed by Benchmark, Altimeter and Salesforce Ventures.
Rain filed the same day
Rain, which runs stablecoin card, wallet and money movement programs for partners, also announced on October 5 that it had applied to the OCC for Rain National Trust Bank, to be headquartered in New York, per its release. Its plan goes further than Modern Treasury’s:
- Custody of digital assets and US dollars as a fiduciary, segregated from the bank’s own assets.
- Reserve management for permitted stablecoin issuers under the GENIUS Act.
- Issuance and redemption of US dollar-backed stablecoins for institutional clients.
Rain National Trust Bank would not accept deposits, offer consumer accounts or make commercial loans. Rain says it will remain a payments platform and a Visa and Mastercard Principal Member through its other subsidiaries. Its proposed president and CEO is Brandon Soto, most recently CFO of Coastal Financial Corporation and earlier CFO of Square Financial Services, Block’s Utah-chartered industrial bank.
What it means for fintechs and banks
| Modern Treasury National Trust Bank | Rain National Trust Bank | |
|---|---|---|
| Custody | Stablecoins and fiat, integrated with payments | Digital assets and US dollars, as fiduciary |
| Stablecoin issuance | No | Yes, for institutional clients |
| Reserve management for issuers | Not stated | Yes |
| Loans | No | No commercial loans |
| Deposits or consumer accounts | Not stated | No |
Rain describes the setup both filings aim to replace: the assets behind its partners’ programs “sit across state licenses, third-party custodians, and third-party stablecoin issuers.” Each charter would move custody into a federally supervised subsidiary of the payments company itself. Rain’s trust bank would take no deposits, and Modern Treasury’s would be limited-purpose, so programs that offer insured bank accounts would still sit with a sponsor bank, as covered in how to choose a sponsor bank.
The filings join a line of payments and crypto firms seeking OCC trust charters. Circle’s approval is in circle national trust bank, Agora’s in Agora National Trust Bank OCC approval, and the OCC’s refusal for Wise in wise national trust bank charter. Community banks are challenging these charters in court, as reported in national trust bank charter lawsuit.
What to watch
- OCC review. Neither bank can open until the OCC grants approval and final authorization.
- Rain’s leadership. Brandon Soto’s appointment as president and CEO is subject to OCC review, per Rain.
- The lawsuit. The court case over OCC trust charters is pending while these applications are reviewed.
