Rain files for OCC trust bank charter to hold stablecoin reserves

Rain, a stablecoin payments company, wants to run its own bank. It filed with the Office of the Comptroller of the Currency on October 5 to set up a national trust bank in New York, the latest crypto firm chasing that federal license.

In a statement that day, the company said the proposed bank, Rain National Trust Bank, would hold digital assets and dollars for institutional clients, manage reserves for stablecoin issuers, and issue and redeem dollar-backed tokens. The bank would act as a fiduciary, keeping customer assets separate from its own. Rain worked with the law firm Paul Hastings on the application.

What Rain wants the bank to do

The plan is deliberately narrow. Rain National Trust Bank would not take deposits. It would not make commercial loans, offer consumer accounts, or carry federal deposit insurance. A trust bank holds and safeguards assets for clients rather than lending them out. Think of it as closer to a safe-deposit vault than a checking account.

Most of its work would sit around stablecoins. Under the GENIUS Act, the US stablecoin law, the bank could hold and manage the reserves that back dollar-pegged tokens, and act as the issuer of record for new ones. Rain said client assets would be custody assets, not deposits the bank could lend against.

Control is the point. Stablecoin firms now lean on outside banks to hold reserves and move dollars. A federal trust charter would let Rain keep that job in house, under one regulator, and cut the middlemen out.

Farooq Malik, Rain's chief executive and co-founder, framed it as trust. Big clients want their money "held by a fiduciary that answers to a federal regulator," he said. Rain itself would stay a payments company and keep its card business, where it is a Visa and Mastercard principal member. The trust bank would be a separate subsidiary, supervised and examined by the OCC.

Why the timing stands out

Rain filed three days after a legal fight landed on the same kind of charter. On October 2, the Independent Community Bankers of America sued the OCC. The group argues the regulator has no authority to hand national trust charters to crypto firms that do not offer normal banking services.

Their complaint is blunt. Letting these firms call themselves trust banks, the bankers say, gives them the look of a bank without the duties that come with taking deposits and making loans. The OCC has said its charter rules clarify existing powers rather than invent new ones.

So Rain is walking into an open question. The agency keeps handing out these charters while a court weighs whether it should. Neither side has a ruling yet.

Rain joins a crowded line

Rain is not first through this door. In December 2025, the OCC gave initial approval to a group of crypto firms, among them Circle, Ripple, BitGo and Fidelity, CoinDesk reported. Circle went on to win final approval for a New York trust bank in late July.

To run the proposed unit, Rain named a banker. Brandon Soto, listed as president and chief executive pending OCC review, is a certified public accountant who was most recently finance chief at Coastal Financial Corporation and earlier held the same role at Square Financial Services. "A trust bank's first job is simple," Soto said. "Know what you hold, know who you hold it for, and keep it safe."

What to watch

The application now sits with the OCC, and the public part of it will appear on the agency's website. A public comment period is built into the review. Rain has not said how much capital the subsidiary would hold, or when it expects an answer.

Two forces will shape the result. One is the lawsuit, which could narrow or confirm the OCC's power to grant these charters. The other is how many more firms file behind Rain, turning a steady trickle of applications into a test of how far the regulator will go. Circle waited from an initial nod in December to final approval in late July, so speed is not the norm.

A filing is a request. It is not a license. Nothing is approved yet, and no charter is guaranteed.