Key Takeaways
- Rain has applied to the OCC to establish a New York-based national trust bank for digital-asset custody and stablecoin services.
- The proposed Rain National Trust Bank would manage stablecoin reserves and issue and redeem dollar-backed stablecoins for institutional clients.
- Rain has named former Square Financial Services CFO Brandon Soto as the proposed CEO of Rain National Trust Bank.
Rain, a stablecoin payments infrastructure company, has applied to the Office of the Comptroller of the Currency (OCC) to establish a national trust bank focused on digital-asset custody, stablecoin reserves, and stablecoin issuance.
According to Rain’s press release, the proposed Rain National Trust Bank (RNTB) would be headquartered in New York and, if approved, operate as a separately capitalized subsidiary. Rain said the bank would bring custody, reserve management, and stablecoin issuance and redemption under a federal supervisory framework.
The application comes only days after the Independent Community Bankers of America (ICBA) sued the OCC over the agency’s framework for national trust bank charters for crypto companies. The legal challenge could create additional uncertainty around the chartering process Rain is entering.
Rain Wants Federal Oversight for Stablecoin Infrastructure
Rain said the proposed bank is intended to address demand from institutions that want digital assets held by a federally supervised fiduciary.
Today, assets supporting Rain’s partners’ stablecoin card, wallet and money-movement programs are held through a combination of state licenses, third-party custodians and outside stablecoin issuers.
If approved, RNTB would allow Rain to bring more of these functions under one federal framework.
Farooq Malik, Rain’s co-founder and CEO, said institutions using Rain want a fiduciary to hold the assets behind their programs and answer to a federal regulator.
Rain itself would remain a payments platform. The proposed trust bank would operate separately from Rain’s existing payments business and would be subject to OCC supervision and examination.
| Detail | Proposed Rain National Trust Bank |
| Applicant | Rain |
| Regulator | Office of the Comptroller of the Currency |
| Name | Rain National Trust Bank |
| Headquarters | New York |
| Main focus | Digital-asset custody and stablecoin services |
| Customers | Institutional clients |
| Deposits | Not permitted |
| Commercial loans | Not permitted |
| Status | OCC application filed, approval pending |
Table 1. Key details of Rain’s proposed national trust bank.
Proposed Bank Would Have Three Main Businesses
Rain said RNTB would focus on three areas if the OCC approves the application.
The first would be fiduciary custody. The proposed bank would safeguard approved digital and fiat assets for institutional clients, with customer assets segregated from the bank’s own assets.
The second would be stablecoin reserve management. RNTB would hold and administer reserves for permitted stablecoin issuers operating under the GENIUS Act, a framework that differs in important ways from how other jurisdictions regulate stablecoin reserves.
The third would be stablecoin issuance and redemption. RNTB could issue U.S. dollar-backed stablecoins as the issuer of record and handle redemptions, subject to the applicable regulatory framework.
Rain said it would not pledge, lend, or reuse reserves backing the stablecoins issued by the proposed bank.
Rain National Trust Bank Would Not Take Deposits
Despite the word “bank” in its proposed name, RNTB would not operate like a traditional retail or commercial bank.
Rain said the proposed institution would be an uninsured national trust bank. It would not accept deposits, provide consumer accounts, or make commercial loans.
Assets held for customers would be treated as custody assets belonging to identified owners rather than liabilities of the bank. This structure distinguishes the proposed institution from banks that accept customer deposits and use those funds as part of their lending activities.
The proposed structure also means customers should not assume that assets held by RNTB would receive FDIC insurance.
Brandon Soto Named Proposed CEO
Rain has selected Brandon Soto as the proposed president and CEO of RNTB, subject to OCC review. Soto most recently served as executive vice president and chief financial officer of Coastal Financial Corporation.
Before that, he was CFO of Square Financial Services, Block’s Utah-chartered industrial bank, where Rain said he helped prepare the bank’s charter application and led finance, treasury and capital management.
He previously served as CFO and Chief Administrative Officer of Green Dot Bank. Rain said Soto’s experience will help build the proposed bank’s controls around asset ownership, reconciliation, capital, and custody.
Rain Enters a Growing Crypto Bank Charter Race
Rain’s application comes as stablecoin regulation, new launches, and market changes continue to grow, with more crypto and payments companies seeking national trust bank charters.
The OCC has received applications from several companies seeking to provide digital-asset services through national trust banks. Its current public list includes applicants such as Zerohash, Dakota National Trust Bank, Payward National Trust Company, EDX Trust, and others.
The OCC has also already conditionally approved national trust bank applications from several digital-asset companies. In December 2025, for example, it conditionally approved applications involving Ripple, First National Digital Currency Bank, BitGo, Fidelity Digital Assets and Paxos.
The growing number of applications reflects crypto companies’ effort to bring custody, stablecoin, and related financial services into federally supervised structures.
OCC Faces Legal Challenge Over Crypto Trust Charters
Rain’s application arrives at a difficult moment for the OCC’s crypto charter program.
The ICBA filed a lawsuit against the OCC on October 2, arguing that the regulator exceeded its authority by allowing national trust banks to conduct activities that community banks say go beyond traditional fiduciary services.
The banking group is seeking to overturn the OCC’s March 2026 chartering rule and related guidance that it says enabled the expansion of crypto trust banks. ICBA also argues that consumers could misunderstand a national trust bank’s status and assume its services carry the same federal protections as conventional insured banks.
The OCC has not indicated that the lawsuit prevents it from accepting or reviewing new applications. Rain’s application will still have to go through the agency’s normal review process.
What Comes Next
Rain National Trust Bank must now go through the OCC’s application and review process, including a public comment period. The proposed institution cannot begin operating until it receives the required approvals.
The outcome of the ICBA lawsuit will also be important because it challenges the regulatory framework under which Rain and other crypto companies are seeking national trust charters. The case could affect how the OCC handles future applications and how much authority national trust banks have over digital assets and stablecoins.
What This Means for You: Rain’s application does not create a new bank or change its existing stablecoin payment services yet. If approved, RNTB would give institutional customers a federally supervised option for digital-asset custody, stablecoin reserve management, and stablecoin issuance, but it would not accept deposits or provide FDIC-insured banking accounts.
