TLDR
- Rain submitted an application to the OCC for Rain National Trust Bank, which would be headquartered in New York City.
- The proposed institution would provide custody services for digital assets, oversee stablecoin reserves, and issue dollar-pegged stablecoins in compliance with the GENIUS Act.
- The submission arrives three days following a lawsuit filed by the Independent Community Bankers of America challenging the OCC’s crypto trust charter framework.
- Brandon Soto, previously CFO at Square Financial Services, has been designated as the intended president and CEO.
- Rain is following in the footsteps of other companies including Circle, Agora, and Zerohash pursuing comparable federal banking charters.
Rain, a company focused on stablecoin payment infrastructure, has submitted an application for a national trust bank charter in the US. The filing was delivered to the Office of the Comptroller of the Currency this past Monday.
Should the application receive approval, the institution will operate under the name Rain National Trust Bank. Its headquarters will be located in New York, functioning under direct OCC regulatory supervision.
Rain will remain a separate entity. The trust banking operations would function as an independently capitalized subsidiary rather than converting the parent company into a bank.
Services Planned for the Trust Bank
The proposed institution would provide fiduciary custody services for both digital assets and US dollar holdings on behalf of institutional customers. Additionally, it would oversee reserve management for licensed stablecoin issuers.
The bank would have authorization to issue and redeem stablecoins backed by US dollars in accordance with guidelines established by the GENIUS Act. Customer assets would remain segregated from the bank’s proprietary holdings at all times.
Rain emphasized that the bank would not accept traditional deposits or provide consumer banking products such as checking or savings accounts. Commercial lending would also be excluded from its business model.
Consequently, the institution would operate without FDIC deposit insurance coverage. Its structure would be limited to that of an uninsured national trust bank.
According to Rain CEO and co-founder Farooq Malik, businesses utilizing Rain’s infrastructure are seeking fiduciary custodianship from an entity overseen by federal banking regulators.
Brandon Soto is the designated candidate for president and CEO of the proposed bank. His background includes serving as CFO at Square Financial Services, followed by a similar role at Coastal Financial Corporation. His appointment remains subject to OCC approval.
Federal Lawsuit Targets Crypto Charter Framework
Rain’s application came just three days following a lawsuit filed by the Independent Community Bankers of America against the OCC. The legal action was initiated on October 2 in the US District Court for the District of Columbia.
The banking group contends that the OCC’s March 2026 chartering regulation permits cryptocurrency firms to access the banking system with less stringent oversight than that imposed on conventional banks. The organization further asserts that consumers might mistakenly associate the designation “national bank” with FDIC deposit insurance.
The complaint names both the OCC and Comptroller Jonathan Gould as defendants. The plaintiffs are requesting the court vacate the regulation along with a corresponding interpretive letter from 2021.
In February, the OCC maintained that the regulation merely clarified its existing chartering authority. The agency emphasized that the rule neither broadened nor diminished its powers.
An OCC representative declined to provide comment on pending litigation.
Rain is part of a growing list of companies seeking this charter type. Circle secured final approval earlier this year for its own institution, known as Circle National Trust.
Agora obtained conditional approval in September. Zerohash filed an amended application in August following the return of an initial submission by regulatory authorities.
Based on information in the community bankers’ legal filing, the OCC has granted either full or conditional approval to no fewer than 21 trust banks. Cryptocurrency-focused firms account for at least 13 of those approvals.
Rain’s submission will undergo a public comment period as part of the OCC’s standard review procedures. The company has not specified when a regulatory decision is expected.
Rain indicated that its existing card, wallet, and money transfer operations will remain unaffected during the review period. The company characterized the trust bank initiative as a multi-year undertaking that will only commence operations after receiving complete regulatory clearance.
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