Rain Seeks US Trust Bank Charter to Custody Crypto and Issue Stablecoins
Key Takeaways
- •Rain filed its application with the OCC to create Rain National Trust Bank, which would operate as a separately capitalized New York subsidiary rather than converting Rain itself into a bank.
- •The proposed institution would offer fiduciary custody of digital assets and US dollars, manage reserves for approved stablecoin issuers, and issue and redeem dollar-backed stablecoins under the GENIUS Act, without accepting deposits or carrying FDIC insurance.
- •Rain has named Brandon Soto, previously CFO at Square Financial Services and Coastal Financial Corporation, as president and CEO of the proposed bank, with his appointment subject to OCC review.
- •The application was submitted three days after the Independent Community Bankers of America sued the OCC in federal court, seeking to overturn the March 2026 chartering rule that enables crypto trust charters.
- •According to the ICBA lawsuit, the OCC has approved or conditionally approved at least 21 trust banks, at least 13 of them crypto companies, with Circle, Agora, and Zerohash among recent applicants.
Rain, a stablecoin payments infrastructure company, has applied for a national trust bank charter in the United States, becoming the latest crypto-focused firm to seek a federal foothold in banking. The company filed its application with the Office of the Comptroller of the Currency (OCC) on Monday, according to an official announcement.
If approved, the new entity will operate as Rain National Trust Bank, headquartered in New York and under OCC supervision. Rain itself would not become a bank; the proposed trust bank would instead run as a separately capitalized subsidiary. The structure would allow Rain to custody digital assets, manage stablecoin reserves, and issue stablecoins directly under federal oversight.
Rain CEO and co-founder Farooq Malik announced the filing in a post on X on October 5:
Rain has filed with the @USOCC to establish Rain National Trust Bank. If approved, the bank will:
- Provide fiduciary custody of digital assets and dollars
- Manage reserves for permitted stablecoin issuers
- Issue and redeem USD-backed stablecoins
Rain will stay a payments…
— farooq 🌧 (@rooqster) October 5, 2026
What the Proposed Bank Would Do
According to the filing, Rain National Trust Bank would offer three core services. It would provide fiduciary custody of digital assets and US dollars for institutional clients, manage reserves for approved stablecoin issu, and issue and redeem dollar-backed stablecoins in accordance with the rules set out in the GENIUS Act, the federal stablecoin law that established reserve and redemption requirements for dollar-pegged payment tokens. Client assets would be kept separate from the bank's own holdings at all times.
The bank would not accept deposits or offer consumer checking and savings accounts, and it would not extend commercial loans. Because of this structure, it would not carry FDIC deposit insurance and would instead function solely as an uninsured national trust bank. National trust charters are a limited-purpose form of national bank charter that the OCC grants to firms carrying out fiduciary activities such as custody, rather than deposit taking and lending.
Malik said the companies building on Rain's infrastructure want their assets held by a fiduciary that reports to a federal regulator.
To lead the proposed bank, Rain has named Brandon Soto as president and CEO. Soto previously served as CFO at Square Financial Services and later at Coastal Financial Corporation. His appointment remains subject to OCC as part of the application process.
Lawsuit Challenges the Rules Behind These Charters
Rain's filing arrived just three days after the Independent Community Bankers of America (ICBA) sued the OCC over its crypto trust charter rules. The lawsuit was filed on October 2 in the US District Court for the District of Columbia.
The banking group argues that the OCC's March 2026 chartering rule allows crypto companies to enter the banking system through lighter oversight than that faced by traditional banks. It also contends that consumers could confuse the term "national bank" with federal deposit insurance protection.
The suit names the OCC and Comptroller Jonathan Gould as defendants and asks the court to overturn both the rule and a related 2021 interpretive letter. The OCC said in February that the rule merely clarified its existing authority, stating that it did not expand or reduce the agency's chartering powers. An OCC spokesperson said the agency does not comment on ongoing litigation.
Part of a Broader Trend
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, and Zerohash submitted a revised application in August after regulators returned an earlier version of its filing.
According to the ICBA's lawsuit, the OCC has approved or conditionally approved at least 21 trust banks, at least 13 of which are crypto companies.
Rain's application will now 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. Two related threads remain open while that review proceeds: the court's handling of the ICBA's bid to overturn the March 2026 rule, and the OCC's decisions on pending applications such as Zerohash's revised filing.
In the meantime, 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 launch only once all required approvals have been granted.
This article originally appeared on CoinCentral.
