Rain wants an OCC charter for a trust bank that would custody digital assets and manage stablecoin reserves without taking deposits or making loans. The application comes as community bankers challenge the regulator’s authority to approve crypto-focused trust banks.
- Rain proposes a separately capitalized national trust bank headquartered in New York.
- The bank would seek authority to custody assets, manage stablecoin reserves and issue stablecoins.
- It would not offer consumer accounts or commercial loans, and it would not have FDIC deposit insurance.
- The OCC has not announced a decision date, and a legal challenge to its chartering framework is pending.
What Rain is asking the OCC to approve
Rain announced on Oct. 5, 2026, that it had applied to the Office of the Comptroller of the Currency (OCC) to establish Rain National Trust Bank. The proposed bank would be headquartered in New York, separately capitalized and supervised by the OCC.
Rain would continue to operate as a stablecoin payments platform. The proposed bank would be a separate operation, providing custody and stablecoin-related services for Rain’s programs and partners.
Rain is asking for permission for the bank to hold approved digital assets and U.S. dollars for clients, manage reserves for permitted stablecoin issuers, and serve as the issuer of record for U.S. dollar-backed stablecoins under the GENIUS Act. The issuer of record is the entity formally responsible for issuing a stablecoin. These are activities Rain is proposing, not powers the OCC has already granted.
Rain says the bank would not accept deposits, offer checking or savings accounts, provide consumer accounts or make commercial loans. It would be an uninsured national trust bank, meaning it would not carry FDIC deposit insurance.
That does not mean the bank could not hold dollars. Rain describes those dollars as assets held in custody or as stablecoin reserves, rather than customer deposits. Custody assets and reserve assets may have different legal treatment and protections from deposits. Rain says client property would be kept separate from the bank’s own assets, and reserves backing stablecoins issued by the proposed bank would not be pledged, lent or reused.
In plain terms, fiduciary custody means holding assets for clients and having legal duties in how those assets are handled. Separating client assets can help distinguish them from a custodian’s own property, but it does not remove every operational, legal or insolvency risk.
Why Rain says it wants a charter
Rain provides infrastructure for stablecoin cards, wallets and money transfers. The company says partners serving millions of end users rely on a mix of state licenses, outside custodians and third-party stablecoin issuers. That figure reflects the reach of partner programs, not necessarily Rain’s direct customers.
Rain CEO and co-founder Farooq Malik said customers want the assets supporting their programs held by a fiduciary overseen by a federal regulator. A national charter could put the proposed bank’s activities under OCC supervision. It would not make the bank an FDIC-insured depository institution or guarantee that every partner or end user has the same protections as a depositor at an insured bank.
The proposed bank would not offer consumer accounts. Rain says its existing card, wallet and money-movement programs will continue while the application is under review. Partners can serve end users through those programs without the proposed bank offering checking or savings accounts.
Rain named Brandon Soto as the proposed bank’s president and CEO, subject to OCC review. Soto previously served as CFO of Square Financial Services and later as CFO of Coastal Financial Corporation. Rain worked with law firm Paul Hastings to prepare its application.
A lawsuit challenges the OCC’s chartering framework
Rain’s application came three days after the Independent Community Bankers of America (ICBA) sued the OCC and Comptroller Jonathan Gould on Oct. 2, 2026. The case, Independent Community Bankers of America v. Office of the Comptroller of the Currency, is numbered 1:2026cv03441 in the U.S. District Court for the District of Columbia and was assigned to Judge Carl J. Nichols.
The ICBA is challenging a March 2026 OCC rule, Interpretive Letter 1176 and the conditional charter approval granted to Protego Holdings. The dispute centers on whether the OCC can use a national trust bank charter to approve activities that the ICBA says go beyond traditional fiduciary services.
The ICBA alleges the agency has “far exceeded” its authority. It is asking the court to find the March rule and Interpretive Letter 1176 unlawful, bar the OCC from using the disputed framework for additional approvals, and vacate Protego’s conditional approval. Those are the group’s claims. The court has not ruled on them.
The OCC says the rule clarified longstanding authority and “neither expands nor contracts” its chartering authority. The rule took effect April 1, 2026. Gould has defended the agency’s approach, saying it assesses whether applicants have a “reasonable chance of success” rather than applying a “zero-risk standard.”
The lawsuit puts the legal scope of the OCC’s trust-bank authority under scrutiny. The outcome could affect the regulatory environment for applicants, but it would not automatically decide Rain’s application. The OCC still has to review Rain’s proposal, and the court has not resolved the ICBA’s claims.
Other crypto firms are pursuing trust bank charters
Rain is not alone. In July 2026, Circle received final OCC approval for First National Digital Currency Bank, which operates as Circle National Trust. Agora received preliminary conditional approval in September 2026 after applying in April. Zerohash submitted a revised application in August 2026 after the OCC returned an earlier filing.
The firms are at different stages. Circle’s approval is described as final, Agora’s as preliminary and conditional, and Rain’s as an application still under review. Conditional approval does not mean a firm has final approval to begin full operations.
Rain describes its proposal as a multi-year initiative. The application is subject to OCC review and a public comment period. Rain expects the public portion to appear on the OCC website. The company says the proposed bank would begin operating only after receiving all required approvals. No decision date has been announced.
Key questions about Rain’s proposed trust bank
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Would Rain National Trust Bank be a regular consumer bank?
No. Rain says it would not accept deposits, offer checking or savings accounts, provide consumer accounts or make commercial loans.
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Would the proposed bank be FDIC-insured?
No. Rain describes it as an uninsured national trust bank. Rain has not said that stablecoin reserves or token holders would have FDIC coverage. The bank’s proposed custody and reserve arrangements should not be confused with insured bank deposits.
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Can Rain issue a stablecoin now?
The application is pending. Rain is seeking authority for the proposed bank to issue dollar-backed stablecoins under the GENIUS Act, but the OCC has not approved the request.
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Has a court ruled on the ICBA lawsuit?
No. The ICBA’s allegations about the OCC’s rule, Interpretive Letter 1176 and Protego’s conditional approval have not been decided.
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When will the OCC decide Rain’s application?
No date has been announced. The application remains subject to OCC review and a public comment period.
The unresolved question is the OCC’s authority
A trust bank could give Rain’s partners a federally supervised way to access custody and stablecoin services while remaining distinct from a conventional deposit-taking bank. The main uncertainty is whether the OCC’s interpretation of its chartering powers will withstand the ICBA’s legal challenge, and how the agency will assess Rain’s requested activities while the dispute is pending.
