Modern Treasury and Rain separately filed applications with the Office of the Comptroller of the Currency (OCC) on Oct. 5, 2026, to establish national trust banks. Modern Treasury National Trust Bank would provide digital-asset custody and related fiat services without taking deposits, making loans, issuing stablecoins or receiving FDIC insurance. Rain National Trust Bank (RNTB), headquartered in New York, would custody digital assets and U.S. dollars, manage reserves for permitted stablecoin issuers under the GENIUS Act, and issue and redeem U.S. dollar-backed stablecoins for institutional clients, while also not accepting deposits, offering consumer accounts or making commercial loans. Both proposed entities would operate as separately capitalized subsidiaries under OCC supervision and remain subject to approval before beginning operations.