TLDR
- Rain has filed an application with the OCC to create Rain National Trust Bank, headquartered in New York.
- The proposed bank would custody digital assets, manage stablecoin reserves, and issue dollar-backed stablecoins under the GENIUS Act.
- The filing comes just days after the Independent Community Bankers of America sued the OCC over its crypto trust charter rules.
- Brandon Soto, former Square Financial Services CFO, is named as proposed president and CEO.
- Rain joins other firms like Circle, Agora, and Zerohash that have sought similar federal charters.
Rain, a stablecoin payments infrastructure company, has applied for a national trust bank charter in the United States. The company filed its application with the Office of the Comptroller of the Currency on Monday.
Rain has filed with the @USOCC to establish Rain National Trust Bank.
If approved, the bank will:
1. Provide fiduciary custody of digital assets and dollars
2. Manage reserves for permitted stablecoin issuers
3. Issue and redeem USD-backed stablecoinsRain will stay a payments…
— farooq 🌧 (@rooqster) October 5, 2026
If approved, the new bank would be called Rain National Trust Bank. It would be based in New York and operate under OCC supervision.
Rain itself would not become a bank. The trust bank would instead run as a separately capitalized subsidiary.
What the Proposed Bank Would Do
The bank would offer fiduciary custody of digital assets and US dollars for institutional clients. It would also manage reserves for approved stablecoin issuers.
It could issue and redeem dollar-backed stablecoins following rules set out in the GENIUS Act. Client assets would be kept separate from the bank’s own holdings.
Rain said the bank would not accept deposits or offer consumer checking and savings accounts. It would not make commercial loans either.
This means the bank would not carry FDIC deposit insurance. It would function only as an uninsured national trust bank.
Rain CEO and co-founder Farooq Malik said the companies using Rain’s infrastructure want their assets held by a fiduciary that reports to a federal regulator.
Brandon Soto has been named as the proposed president and CEO. He previously worked as CFO at Square Financial Services and later at Coastal Financial Corporation. His appointment still needs OCC review.
Lawsuit Challenges the Rules Behind These Charters
Rain’s filing arrived three days after the Independent Community Bankers of America sued the OCC. The lawsuit was filed on October 2 in the US District Court for the District of Columbia.
The group argues the OCC’s March 2026 chartering rule lets crypto companies enter the banking system through lighter oversight than traditional banks face. It also claims consumers could confuse the term “national bank” with federal deposit insurance protection.
The lawsuit names the OCC and Comptroller Jonathan Gould as defendants. It asks the court to overturn the rule and a related 2021 interpretive letter.
The OCC said in February that the rule only clarified its existing authority. The agency stated the rule did not expand or reduce its chartering powers.
An OCC spokesperson said the agency does not comment on ongoing litigation.
Rain is not the only company pursuing this type of charter. Circle received final approval earlier this year for its own national trust bank, called Circle National Trust.
Agora received conditional approval in September. Zerohash submitted a revised application in August after an earlier version was returned by regulators.
According to the community bankers’ lawsuit, the OCC has approved or conditionally approved at least 21 trust banks. At least 13 of those are crypto companies.
Rain’s application will go through a public comment period as part of the standard OCC review process. The company has not given a timeline for when a decision might arrive.
Rain said its card, wallet, and money transfer services will continue operating as usual while the application is under review. The company described the trust bank project as a multi-year effort that will only launch once all approvals are granted.
