Rain has filed an application to establish a U.S. national trust bank capable of digital asset custody, stablecoin reserve management and dollar-backed stablecoin issuance. The Office of the Comptroller of the Currency must approve the plan.
The proposed Rain National Trust Bank would operate as a separately capitalized subsidiary headquartered in New York under direct OCC supervision. Rain, a stablecoin payments platform, would remain separate from the bank itself, according to the company's Oct. 5 announcement.
Three core business lines anchor the proposed institution for institutional clients: fiduciary custody for approved digital assets and U.S. dollars, with client property held separately from bank assets; reserve management for permitted stablecoin issuers; and issuance of U.S. dollar-backed stablecoins under the GENIUS Act, a federal framework for payment stablecoin issuers that establishes reserve requirements and audit standards.
Rain CEO and co-founder Farooq Malik said customers using the company's infrastructure require their program-supporting assets to be held by a fiduciary under federal regulatory oversight. "The proposed bank is a distinct operation designed to hold client assets subject to OCC examination," he said.
Rain currently provides infrastructure for stablecoin cards, wallets and money transfers, with partners serving millions of end users through state licenses, external custodians and third-party stablecoin issuers. The charter application seeks to consolidate some of these functions into a federally regulated trust bank.
Brandon Soto has been named proposed president and CEO of Rain National Trust Bank, pending OCC approval. Soto previously served as chief financial officer for Square Financial Services, Block's Utah-chartered industrial bank, and later held the CFO position at Coastal Financial Corporation.
The proposed bank would not accept deposits, offer checking or savings accounts, provide consumer accounts or make commercial loans. It would operate as an uninsured national trust bank without FDIC deposit insurance. Client assets placed in custody retain their identification as client assets rather than bank liabilities, and reserves supporting any stablecoin issued by the proposed institution would not be pledged, lent or reused.
Rain's application arrived three days after the Independent Community Bankers of America filed a federal lawsuit challenging the OCC's existing legal framework for national trust bank charters. The challenge positions Rain's bid within a growing conflict over how crypto and payments firms integrate into the federal banking system.
