Rain has applied to the Office of the Comptroller of the Currency (OCC) — the U.S. Treasury bureau that charters and supervises national banks — to establish a U.S. national trust bank, the payments company announced on Oct. 5. The proposed New York-based subsidiary, named Rain National Trust Bank, would hold digital assets and dollars in fiduciary custody, manage stablecoin reserves, and issue and redeem dollar-backed stablecoins for institutional clients.

The charter has not been approved. Rain says the limited-purpose bank would not accept deposits, offer consumer accounts, or make commercial loans, and would not be FDIC insured.

If approved, the change would give Rain's partners an additional provider for the assets behind their payment programs. According to the company, those assets currently sit across state licenses, third-party custodians, and outside stablecoin issuers. The proposed bank would consolidate custody, reserve management, and issuance under one federally supervised subsidiary rather than immediately replace the existing arrangements, bringing those functions under a single federal supervisor.

Custody, Reserves and Leadership

"Rain will stay a payments platform," CEO and co-founder Farooq Malik wrote on X.

Rain says the separately capitalized bank would hold client custody assets apart from its own corporate assets. It would administer reserves for permitted stablecoin issuers under the GENIUS Act, the federal stablecoin framework signed into law in July 2025, and could itself become the issuer of record. Reserves backing stablecoins it issues would not be pledged, lent, or reused, the company said.

Brandon Soto is proposed as president and CEO, subject to OCC review. He most recently served as chief financial officer of Coastal Financial Corporation and previously held the same role at Square Financial Services, where Rain says he helped prepare the bank's charter application.

Rain lists more than 200 partners and is a principal member of Visa and Mastercard. Its existing model is visible in Western Union's Stablecard, which launched in 37 markets in August using Rain's wallet and card infrastructure. That product uses USDPT, issued by Anchorage Digital Bank, rather than a Rain-issued token.

A Contested Charter Path

Rain joins other digital-asset businesses seeking federal trust charters. The OCC's published pending-applications list includes zerohash national trust bank, Dakota National Trust Bank, and Payward National Trust Company.

The route is also under legal challenge. On Oct. 2, the Independent Community Bankers of America sued the OCC, arguing that the agency exceeded its authority by allowing national trust banks to conduct non-fiduciary crypto activities. The complaint seeks to invalidate a March chartering rule and a 2021 interpretive letter. When it issued the rule, the OCC said it clarified longstanding authority rather than expanded it.

Rain describes its proposed bank as a "multi-year initiative" and says existing card, wallet, and money-movement programs will continue unchanged. It expects the public application to appear on the OCC's website in the coming days, with a public comment period forming part of the review. Operations would begin only after all required approvals. How the OCC handles the application and how the ICBA lawsuit proceeds are the two threads to watch as the process unfolds.