Stablecoin payments infrastructure firm Rain has filed an application with the U.S. Office of the Comptroller of the Currency to create Rain National Trust Bank, a New York-headquartered national trust bank that would custody digital assets and U.S. dollars, manage reserves for permitted stablecoin issuers, and issue or redeem U.S. dollar-backed stablecoins under the federal GENIUS Act.
The proposed bank would operate as a separately capitalized subsidiary under OCC supervision. Rain itself would remain a stablecoin payments platform and would not become the bank. The institution would not accept deposits, offer consumer checking or savings accounts, or make commercial loans. It would be an uninsured national trust bank without FDIC deposit insurance, and client assets held in custody would remain separate from the bank's own assets. Stablecoin reserves would not be pledged, lent, or reused.
Rain CEO and co-founder Farooq Malik said companies using Rain's infrastructure want assets supporting their programs held by a fiduciary overseen by a federal regulator. The company named Brandon Soto as proposed president and CEO, subject to OCC review. Soto previously served as CFO of Square Financial Services and later as CFO of Coastal Financial Corporation. Rain worked with law firm Paul Hastings on the application, which will include a public comment period.
The filing arrived three days after the Independent Community Bankers of America sued the OCC and Comptroller Jonathan Gould on Oct. 2 in the U.S. District Court for the District of Columbia. The lawsuit, case number 1:2026cv03441 before Judge Carl J. Nichols, challenges a March 2026 OCC rule, Interpretive Letter 1176, and the conditional approval granted to Protego Holdings. The ICBA argues the OCC has exceeded its authority by allowing national trust banks to conduct non-fiduciary activities under limited-purpose charters. The OCC has said the rule clarified existing authority and did not expand or contract its chartering powers.
Rain joins a wave of crypto and payments firms seeking similar federal charters. Circle received final OCC approval in July for First National Digital Currency Bank, operating as Circle National Trust. Agora received preliminary conditional approval in September, and Zerohash submitted a revised application in August. According to the community bankers' lawsuit, the OCC has approved or conditionally approved at least 21 trust banks, at least 13 of which are crypto companies. Rain said the national trust bank project is a multi-year initiative and its existing card, wallet, and money transfer services will continue while the OCC review proceeds.
