Rain, a stablecoin payments infrastructure company, has filed an application with the U.S. Office of the Comptroller of the Currency (OCC) to establish a national trust bank focused on digital asset custody and stablecoin services.
The company announced the application on October 5, saying the proposed bank would bring functions currently handled through state licenses, third-party custodians, and stablecoin issuers under federal supervision. Headquartered in New York, the bank would operate as a separate subsidiary of Rain if the application is approved.
Rain’s partners currently run stablecoin card, wallet and money movement programs serving millions of end users. According to Rain, the proposed structure would give those programs access to federally supervised custody and stablecoin services while allowing Rain to continue operating its payments business separately.
Rain Proposes National Trust Bank
If approved, Rain National Trust Bank would serve institutional clients across three main areas: custody, reserve management, and stablecoin issuance and redemption.
The bank would provide fiduciary custody for approved digital assets and U.S. dollars, with client assets segregated from the bank’s own assets. It would also hold and administer reserves for permitted stablecoin issuers, subject to applicable requirements, including those established under the GENIUS Act.
RNTB would also be able to issue and redeem U.S. dollar-backed stablecoins as issuer of record, subject to the applicable regulatory requirements.
Rain CEO and co-founder Farooq Malik said institutional clients want assets supporting their programs to be held by a fiduciary under federal oversight. “Rain National Trust Bank is how we plan to meet that expectation,” Malik said.
Rain Will Not Accept Deposits
The proposed bank would have a limited business model and would not operate like a traditional commercial bank.
Rain said RNTB would be an uninsured national trust bank and would not accept deposits, offer consumer accounts or make commercial loans. Client assets held by the bank would be custody assets belonging to identified owners rather than liabilities of the bank. The reserves backing any stablecoins issued by RNTB would also not be pledged, lent, or reused.
Rain itself would remain a stablecoin payments platform and a Visa and Mastercard principal member through its other subsidiaries. RNTB would instead be separately capitalized and subject to OCC supervision and examination if approved.
Brandon Soto Named Proposed CEO
Rain has named Brandon Soto as the proposed president and CEO of Rain National Trust Bank, subject to OCC review.
Soto most recently served as executive vice president and chief financial officer of Coastal Financial Corp. Before that, he was CFO of Square Financial Services, Block’s Utah-chartered industrial bank.
Soto helped prepare Square Financial Services’ charter application and led its finance, treasury and capital management functions. He previously served as CFO and chief administrative officer of Green Dot Bank. Soto said the proposed bank would emphasize clear ownership records, daily reconciliation, strong controls and appropriate capitalization.
OCC Review Next
Rain’s application is now subject to OCC review and approval, including a public comment period. The OCC maintains a public database of pending digital-asset licensing applications, with public portions of applications made available when they are subject to public comment.
The public portion of Rain’s application is expected to be made available on the OCC’s website once posted by the regulator.
The proposed bank cannot begin operations until it receives all required approvals. Rain said it worked with Paul Hastings to prepare the application and will continue working with the OCC throughout the review process.
Rain’s application comes as other crypto and fintech companies seek similar national trust bank charters. Modern Treasury has also applied to establish a national trust bank that would provide federally supervised digital asset custody and related fiat services alongside its existing payments business.
Stablecoin firm Agora received preliminary conditional approval from the OCC in September to establish Agora National Trust Bank. If it receives final approval and meets the regulator’s conditions, the proposed bank would oversee parts of Agora’s stablecoin, custody and transaction operations.
Rain’s proposed trust bank would add a federally supervised layer to the company’s existing stablecoin payments infrastructure, if approved. For now, the application remains under regulatory review, with the OCC’s decision and public comment process expected to determine the next stage of the project.
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