TLDR
- Rain filed an application with the OCC on Oct. 5 to create Rain National Trust Bank in New York.
- The proposed bank would hold assets in custody, manage stablecoin reserves, and issue dollar-backed stablecoins under the GENIUS Act.
- It would not take deposits, offer consumer accounts, make commercial loans, or carry FDIC insurance.
- Former Square Financial Services CFO Brandon Soto is the proposed president and CEO.
- The filing came three days after community bankers sued the OCC over its trust charter rules.
Stablecoin payments company Rain has filed an application to set up a national trust bank in the United States. The company announced the filing with the Office of the Comptroller of the Currency, or OCC, on Oct. 5.
The proposed Rain National Trust Bank would be based in New York. It would be a separately funded subsidiary under OCC supervision, while Rain itself would remain a payments platform.
What Rain National Trust Bank Would Do
If approved, the bank would serve institutional clients through three business lines. It would hold approved digital assets and U.S. dollars in custody, with client assets kept separate from the bank’s own funds.
It could also manage reserves for permitted stablecoin issuers under the federal GENIUS Act. The bank could act as issuer of record for U.S. dollar-backed stablecoins as well.
Rain CEO and co-founder Farooq Malik said institutions using Rain want their assets held by a fiduciary that answers to a federal regulator. He said the trust bank would be a separate subsidiary subject to OCC examination.
Rain provides infrastructure for stablecoin cards, wallets and money transfers. Its partners serve millions of users and currently rely on state licenses, outside custodians and third-party stablecoin issuers.
The bank would not accept deposits, offer consumer accounts or make commercial loans. It would be an uninsured trust bank, so it would not carry FDIC insurance.
Rain said reserves backing any stablecoin the bank issues would not be pledged, lent or reused. Client assets would remain the property of their owners, not liabilities of the bank.
Brandon Soto has been named proposed president and CEO, subject to OCC review. He was most recently CFO of Coastal Financial Corporation and earlier served as CFO of Square Financial Services, Block’s Utah-chartered industrial bank.
“A trust bank’s first job is simple. Know what you hold, know who you hold it for, and keep it safe,” Soto said.
Community Bankers Challenge the OCC in Court
Rain’s filing came three days after the Independent Community Bankers of America sued the OCC and Comptroller Jonathan Gould. The lawsuit was filed Oct. 2 in federal court in Washington, D.C., and assigned to Judge Carl J. Nichols.
The group challenges a March 2026 OCC rule, Interpretive Letter 1176 and a conditional approval granted to Protego Holdings. It argues the OCC has “far exceeded” its authority by letting trust banks conduct non-fiduciary activities. The court has not ruled on the claims.
The OCC has said its rule, which took effect April 1, only clarifies longstanding authority. The agency said the rule neither expands nor reduces its chartering powers.
Other crypto firms are already in the charter process. Circle received final OCC approval in July, Agora won preliminary conditional approval in September, and Zerohash filed a revised application in August.
Rain worked with law firm Paul Hastings on its application. The company called the project a multi-year effort and said its current card, wallet and money movement programs will continue unchanged.
The OCC review will include a public comment period, and no decision date has been set. An OCC spokesperson said Monday the agency does not comment on litigation, and the public portion of Rain’s application is expected on the OCC website in the coming days.
