Rain Pushes Into U.S. Banking With Stablecoin Trust Charter as OCC Faces Legal Challenge

Rain has submitted an application to the Office of the Comptroller of the Currency to form a new national bank in New York called Rain National Trust Bank to provide services to institutional customers related to digital asset custody and stablecoins․ Rain would form the national bank as a separate legal entity but would continue to offer other services through its existing stablecoin payment platform․

If implemented‚ the trust bank would hold and safeguard digital and U․S․ dollar assets for clients and other acceptance and reserve bank functions for eligible stablecoin issuers and issue dollar stablecoins on behalf of others under the proposed GENIUS Act․ Client assets would be kept separate from the trust bank’s assets․

Rain Targets Federal Oversight for Stablecoin Infrastructure

Rain CEO and co-founder Farooq Malik said customers prefer to have assets related to their programs managed by a federal regulator․ Rain offers services related to stablecoins‚ including cards and payment services․ Partners use other services and licenses from state regulators and custodians‚ as well as stablecoins issued by other providers․

The proposed entity would not be a traditional retail bank․ It would not offer deposit products or checking and savings accounts to individual or business customers․ Rain National Trust Bank would not be FDIC-insured․ Rain stated that funds held in reserve for a stablecoin product offered by Rain National Trust Bank would not be used as collateral or lent to other parties․

Brandon Soto has been nominated as president and CEO‚ pending OCC approval․ Mr․ Soto’s prior experience includes serving as CFO of Square Financial Services‚ a Utah-chartered industrial bank owned by Block‚ and CFO of Coastal Financial Corporation․

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Rain‚ along with other digital asset companies‚ seeks a narrow federal charter to provide custody and stablecoin services but not deposit services․

Rain’s OCC Bid Lands in the Middle of a Charter Lawsuit

The filing was made as part of a lawsuit about the OCC’s‌ trust bank charter authority․ On October 2‚ the‌ Independent Community Bankers of America filed a lawsuit in federal court against the OCC and Comptroller Jonathan Gould‚ challenging the OCC’s power to permit national trust banks to engage in non-trust activities․

The lawsuit contests the OCC’s March 2026 rule and interpretive letter 1176 and conditional‌ charter approval for Protego Holdings․ ICBA claims the OCC‌ acted outside its legal authority by approving trust charters for non-fiduciary purposes․ All allegations in the lawsuit are unverified by‌ the court․

The OCC states that its new rule does not increase its national bank chartering powers․ The OCC explained in a February bulletin that the rule simply makes clear the authority that national trust banks have long had to engage in non-fiduciary activities in addition to fiduciary activities․ The rule was effective April 1‚ 2026․

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Rain’s application for approval must go through OCC review and another public comment period․ Dates for approval decisions were not announced․ Current Rain card and money transfer and wallet products will continue while the application is pending‚ and the new bank cannot open for business until it receives necessary regulatory approvals․

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