Rain has reportedly applied to establish Rain National Trust Bank, a proposed New York-based institution that could hold digital assets and U.S. dollars in fiduciary custody and support stablecoin reserves and transactions if the OCC approves it. The report came days after the Independent Community Bankers of America (ICBA) announced a lawsuit challenging the OCC framework for crypto-related national trust charters. No Rain-specific OCC application record or approval was established in the available OCC materials.
What Rain is applying to do
Cointelegraph reported on October 6, 2026, that Rain, a stablecoin payments infrastructure provider, had filed an application with the Office of the Comptroller of the Currency (OCC) to establish Rain National Trust Bank, headquartered in New York. The report said the filing was made on Monday, October 5, but did not provide an application control number or a Rain-specific public OCC record. Cointelegraph reported the application.
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The bank and its services remain proposals, not operating services. According to the report, the proposed institution could, if approved:
- Provide fiduciary custody of digital assets and U.S. dollars for institutional clients.
- Manage reserves for permitted stablecoin issuers.
- Issue and redeem dollar-backed stablecoins under the GENIUS Act.
The report names former Square Financial Services CFO Brandon Soto as the proposed bank’s president and CEO, subject to OCC review. It does not establish that he has taken the role.
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Has the OCC approved Rain’s charter?
No approval is established by the materials available for this report. The OCC’s Digital Assets Licensing Applications page describes its table as covering pending applications from entities planning digital asset products or services; the version checked did not list Rain. That absence does not disprove the reported filing: the news report may have preceded OCC intake or public posting.
The OCC says its Corporate Applications Search (CAS) displays application status and actions, with a five-day delay between receipt and visibility. To check for a public record, search by applicant name and date range after that interval. If a record appears, review its application number, status, any comment period, and subsequent actions. The OCC’s chartering unit says it receives and analyzes filings and works with legal and supervisory divisions on decisions supported by factual, legal, and supervisory analysis; a reported filing is not an approval.
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Why the ICBA lawsuit matters
On October 2, 2026, the ICBA announced a lawsuit challenging the OCC’s March 2026 National Bank Chartering rule and Interpretive Letter 1176. Cointelegraph reported that the suit seeks to overturn the rule and letter and prevent further approvals relying on them. The ICBA newsroom announcement confirms the association’s announcement.
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What a trust charter does—and what remains unclear
A national trust bank charter is not, by itself, the same thing as approval to operate every service a conventional deposit-taking bank offers. The specific activities a chartered institution may conduct depend on the approved scope and applicable law. Rain’s reported proposal centers on fiduciary custody, reserve management, and stablecoin issuance and redemption; the application record was not available to confirm the precise requested powers or conditions.
The available information also does not establish that Rain’s proposed bank would take retail deposits or that customer balances would have FDIC insurance. Those questions should not be inferred from the phrase “national trust bank”; they require confirmation from the application, OCC decisions, and applicable disclosures.
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What Rain says about the application
Cointelegraph attributed this statement to Rain CEO and co-founder Farooq Malik: “The institutions building on Rain want the assets behind their programs held by a fiduciary that answers to a federal regulator.” It describes Rain’s stated rationale for seeking a federally supervised fiduciary, not an assurance that the charter will be granted.
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