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ZEC $1,335 Modern Treasury files for US trust bank charter to custody stablecoins
The payments company wants a federally regulated, limited-purpose national trust bank to custody stablecoins and fiat for its customers.
Key takeaways
- The custody bank. Modern Treasury would custody stablecoins and fiat for customers but would not issue stablecoins or make loans.
- Payments scale. Its existing payments business has facilitated more than $600 billion in payments across hundreds of organizations.
- A crowded queue. The ICBA complaint says the OCC has approved or conditionally approved at least 21 trust banks, at least 13 of them crypto companies.
What happened
Modern Treasury has applied to the Office of the Comptroller of the Currency to establish Modern Treasury National Trust Bank. The proposed entity would be a federally regulated, limited-purpose national trust bank that provides digital asset custody and related fiat services.
If approved, the bank would let Modern Treasury customers custody and move stablecoins and fiat through an integrated service. It would not issue stablecoins or make loans. Co-founder and CEO Matt Marcus said the company believes stablecoins are foundational economic infrastructure for the future.
Stablecoin payments infrastructure provider Rain filed its own application for a national trust bank headquartered in New York, with Brandon Soto named as proposed president and CEO subject to OCC review. Rain's application arrived three days after the Independent Community Bankers of America sued the OCC, alleging the regulator exceeded its authority by letting trust banks that take no deposits carry out wide non-fiduciary activities.
Why it matters
Modern Treasury is not alone in the queue. Bastion and Ripple have received conditional approvals, while Circle and BitGo have received final approvals. Kraken parent Payward, Zerohash and Block have also submitted applications.
The ICBA lawsuit challenges the framework behind those bids. The group asked the court to overturn the OCC's March 2026 chartering rule and a 2021 interpretive letter, and to prevent further charter approvals that rely on them. The ICBA also said the framework gives crypto trust banks a competitive advantage over community banks.
The ICBA alleged consumers could mistake the "national bank" designation for assurance that their assets are federally insured. The OCC says its April charter rule clarified existing authority and did not expand powers. The Crypto Council for Innovation said the lawsuit was an attempt to stifle innovation.
What the data shows
Modern Treasury said the proposed bank would run separately from its existing payments business, which the company says has handled more than $600 billion in payments for hundreds of organizations.
According to the ICBA's complaint, the OCC has approved or conditionally approved at least 21 trust banks, at least 13 of which are crypto companies.
Rain announced its application on Oct. 5. The proposed Rain National Trust Bank would be based in New York and operate as a separately capitalized subsidiary under OCC supervision. It would not accept deposits, offer consumer accounts or make commercial loans, and it would be uninsured, without FDIC deposit insurance.
If approved, Rain's bank could hold digital assets and US dollars in fiduciary custody for institutional clients, run reserves for permitted stablecoin issuers and issue dollar-backed stablecoins under the GENIUS Act.
What is still unclear
- The reports do not state when the OCC will decide on Modern Treasury's application.
- The reports do not say how the ICBA lawsuit will affect pending charter applications.
Questions readers ask
What is Modern Treasury National Trust Bank?
It is the entity Modern Treasury applied to the OCC to establish. It would operate as a federally regulated, limited-purpose national trust bank offering digital asset custody and related fiat services, and it would not issue stablecoins or make loans.
Why is the ICBA suing the OCC over crypto trust charters?
The Independent Community Bankers of America alleged the regulator exceeded its authority by allowing non-depository trust banks to conduct extensive non-fiduciary activities. The group asked the court to overturn the OCC's March 2026 chartering rule and a 2021 interpretive letter.
Which firms have US trust bank approvals already?
Bastion and Ripple have received conditional approvals, while Circle and BitGo have received final approvals. Kraken parent Payward, Zerohash and Block have also submitted applications.
Will the proposed Rain trust bank take customer deposits?
No. Rain National Trust Bank would not accept deposits, offer consumer accounts or make commercial loans, and it would operate as an uninsured national trust bank without FDIC deposit insurance.
