Rain Files OCC Application for National Trust Bank to Custody Crypto and Issue Stablecoins

Rain, the enterprise stablecoin payments infrastructure company, filed an application with the Office of the Comptroller of the Currency on October 5 to establish Rain National Trust Bank, a proposed national trust bank headquartered in New York. If approved, the trust bank would provide fiduciary custody of digital assets and U.S. Dollars, manage reserves for permitted stablecoin issuers, and issue and redeem dollar-backed stablecoins for institutional clients.

The application arrives as the OCC faces a federal lawsuit from the Independent Community Bankers of America challenging the legal framework that allows crypto firms to obtain national trust bank charters. The trade group filed suit on October 2 arguing the OCC exceeded its authority by permitting national trust banks to conduct non-fiduciary activities under limited-purpose charters.

What does Rain National Trust Bank propose to do?

Rain National Trust Bank would operate three distinct lines of business for institutional clients. Custody services would safeguard approved digital and fiat assets as a fiduciary, with client assets segregated from the bank's own balance sheet. Reserve management would hold and administer reserves for permitted stablecoin issuers under the GENIUS Act framework signed into law June 18, 2025. Issuance and redemption would allow RNTB to act as issuer of record for U.S. Dollar-backed stablecoins and handle redemptions under the same statutory authority.

The proposed bank would not accept deposits, offer consumer checking or savings accounts, or make commercial loans. Assets held for clients would be custody assets belonging to identified owners, not liabilities of the bank. Reserves backing any stablecoin RNTB issues could not be pledged, lent, or reused. Rain itself would remain a stablecoin payments platform and Visa and Mastercard Principal Member through its other subsidiaries; RNTB would be a separately capitalized entity supervised and examined by the OCC.

Why is Rain pursuing a federal trust charter now?

The institutions building on Rain's infrastructure want the assets behind their programs held by a fiduciary that answers to a federal regulator, according to CEO and co-founder Farooq Malik. Today those assets sit across state licenses, third-party custodians, and third-party stablecoin issuers. A national trust bank would consolidate custody, reserve management, and stablecoin issuance and redemption under a single federal supervisory framework.

Rain's partners run stablecoin card, wallet, and money movement programs serving millions of end users. The company hit a $1.95 billion valuation in January 2026 after raising $250 million in Series C funding led by ICONIQ. The trust bank initiative is a multi-year project that would add a federally supervised option alongside existing infrastructure rather than replace current partnerships.

Who will lead the proposed trust bank?

Brandon Soto will serve as proposed president and chief executive officer of Rain National Trust Bank, subject to OCC review. Soto most recently served as executive vice president and chief financial officer of Coastal Financial Corporation. Before that he was chief financial officer of Square Financial Services, Block's Utah-chartered industrial bank, where he helped prepare the charter application approved by the FDIC and the Utah Department of Financial Institutions. Earlier he served as chief financial officer and chief administrative officer of Green Dot Bank.

His appointment brings direct experience working through the de novo charter process for a fintech-affiliated industrial bank. The OCC will evaluate Soto's qualifications as part of its review of the application's management competence, a standard factor in all charter decisions.

How does the ICBA lawsuit affect Rain's application?

The Independent Community Bankers of America sued the OCC on October 2 in the U.S. District Court for the District of Columbia, challenging the agency's March 2026 chartering rule and a 2021 interpretive letter. The complaint argues the OCC has far exceeded its authority by allowing national trust banks to conduct non-fiduciary activities under limited-purpose charters. The trade group also alleges the charter framework lacks requirements applied to insured banks including capital and liquidity standards, consolidated supervision, and FDIC coverage.

The OCC has not indicated the lawsuit prevents it from accepting or reviewing new applications. The agency's February bulletin accompanying the March rule stated the change merely clarifies its longstanding authority to let national trust banks conduct non-fiduciary activities alongside fiduciary work and neither expands nor contracts its chartering authority. Rain's application will still go through the OCC's normal review process including a public comment period.

What precedent exists for crypto trust bank charters?

The OCC has approved or conditionally approved 21 national trust banks, at least 13 of them crypto companies, according to the ICBA complaint. In December 2025 the agency conditionally approved five applications in a single day: Circle's First National Digital Currency Bank, Ripple National Trust Bank, Paxos Trust Company conversion, BitGo Bank & Trust conversion, and Fidelity Digital Assets conversion. Since then Coinbase National Trust Company received preliminary conditional approval in April 2026, Agora National Trust Bank in 2026, Bastion Platforms Trust Company converted to a national trust bank, and Protego's National Digital Trust Company received preliminary conditional approval. World Liberty Financial, issuer of the USD1 stablecoin, won conditional approval in August 2026.

These approvals mark a significant shift in federal banking oversight of digital asset activities. The conditional approvals all require compliance with the GENIUS Act and implementing regulations for stablecoin issuance activities. The OCC has also adjusted regulatory capital treatment for reserve assets backing issued stablecoins in at least one approval, signaling willingness to recalibrate oversight for this business model.

What happens next in the review process?

The application is subject to OCC review and approval, including a public comment period. The public portion of the application will be available on the OCC's website at occ.gov. Rain leadership and RNTB's organizers recognize the responsibility that comes with seeking a national trust bank charter and will work diligently with the OCC throughout the process. No timeline for a decision has been provided; the OCC follows its own review timetable.

The proposed bank can begin operations only after receiving all required approvals. Rain's existing card, wallet, and money movement programs will remain in place while the OCC reviews the charter application. The outcome of the ICBA lawsuit will also be significant because it challenges the legal foundation the OCC uses for these charters.

What does this mean for stablecoin users and issuers?

If approved, Rain National Trust Bank would give institutional customers a federally supervised option for digital-asset custody, stablecoin reserve management, and stablecoin issuance and redemption. The trust bank would operate under OCC examination with fiduciary duties for custody services and statutory requirements for reserve management under the GENIUS Act. It would not provide FDIC-insured banking accounts or accept retail deposits.

For stablecoin issuers, RNTB could serve as a reserve manager and technology provider for minting, burning, and redeeming tokens while the issuer retains control over its program. For end users of Rain's partner programs, the change would be largely invisible in the near term since existing infrastructure continues operating during the review period. The long-term significance depends on whether the federal trust bank model becomes the dominant structure for stablecoin infrastructure in the United States.