Rain filed on Monday with the Office of the Comptroller of the Currency to establish Rain National Trust Bank, a proposed New York-based trust that would hold client assets, manage stablecoin reserves and issue dollar-backed stablecoins under the GENIUS Act. The filing arrived three days after a community bank group sued the OCC over the charter framework it would use to approve the application.
Rain builds the plumbing behind stablecoin card programs, wallets and money movement, and its partners serve millions of end users. Today the assets behind those programs sit spread across state licenses, third-party custodians and outside issuers. A single federal charter would fold custody, reserve management and issuance under one OCC-supervised roof, and that consolidation is the whole point of the application.
What the bank would and would not do
If approved, Rain National Trust Bank would run three lines of business for institutional clients: fiduciary custody of approved digital and fiat assets with client property segregated from the firm’s own holdings, reserve administration for permitted stablecoin issuers, and issuance and redemption of dollar-backed stablecoins as issuer of record. Brandon Soto is lined up as the unit’s proposed president and chief executive, subject to OCC review.
The exclusions matter as much as the powers. The bank would not accept deposits, offer consumer accounts or make commercial loans, which means no FDIC insurance. Assets held in custody stay property of identified clients rather than liabilities of the bank. And reserves backing any stablecoin it issues would not be pledged, lent or reused. Rain itself remains a payments platform and a Visa and Mastercard principal member through other subsidiaries, and the charter project is described as a multi-year effort that starts only after every approval lands.
“The institutions building on Rain want the assets behind their programs held by a fiduciary that answers to a federal regulator,” said Farooq Malik, the company’s CEO and co-founder.
The lawsuit hanging over the queue
The timing puts the application inside a live legal fight. On October 2 the Independent Community Bankers of America sued the OCC in federal court in Washington, arguing the agency exceeds its authority when it grants limited-purpose trust charters to crypto and fintech firms. The challenge targets an OCC rule in force since April 1 that allows trust-only national banks to run non-fiduciary activities connected to their trust business.
Safekeeping fits the traditional definition of fiduciary work comfortably. Issuing a payment token fits less obviously, and whether an issuer of record can sit inside a trust charter is exactly what the complaint contests. A ruling for the ICBA could stall the queue of pending applications, which is a crowded one.
| Company | Charter status | Custody | Issuance |
|---|---|---|---|
| Rain | Applied, October 2026 | Yes, planned | Yes, under GENIUS Act |
| Circle | Final approval, July 2026 | Yes | Separate entity |
| Modern Treasury | Applied, October 2026 | Yes | None planned |
| Coinbase | Conditional approval, April 2026 | Yes | None planned |
The table shows what Rain is actually asking for: no other applicant combines custody, reserve management and issuance in one charter. Circle already has its approval, but its issuance business runs through a separate entity. If the OCC approves Rain as filed, it becomes the first stablecoin payments platform to own every step of a card payment in-house, from token creation through network settlement.
Why the charter route at all
The fragmented stack costs money and invites failure points. A partner running a stablecoin card program currently depends on a state money transmitter license, a third-party custodian and a separate issuer, each with its own examinations and each a place where something can go wrong or be renegotiated at renewal time. Vertical integration under a federal regulator removes several of those seams, which is the argument institutional clients are making when they ask for a fiduciary that reports to Washington rather than to a state.
The regulatory environment has moved the other direction this month, which might look like a detour but points the same way. FinCEN withdrew two proposed rules on Sunday, dropping the $10,000 crypto transfer reporting requirement for self-custody wallets and a mixer designation framework under the PATRIOT Act, and the SEC put out a custody proposal that lets advisers self-custody in narrow cases. The perception in Congress and at the agencies is that the tightening cycle is over. Charter-seekers read that as a window that will not stay open indefinitely.
Timing on the other side is less helpful. The OCC is still writing the GENIUS Act regulations on reserves and permitted issuers that define Rain’s issuance business, and those rules will shape what an approved bank can actually do. Applications filed before final rules land bet that the framework matches the draft’s direction, a bet Circle effectively placed and won earlier this year.
Legal risk is real but historical precedent does not favor the challengers. Charters for non-bank trust companies have been granted for decades, though never at this pace or with this business mix, and the community bank lobby has challenged crypto-adjacent charters before without stopping them. What is genuinely new is scale and speed, and those are the grounds the judge will hear arguments on.
Rain has no date for an OCC decision, which follows its own review timetable and includes a public comment window. The public portion of the application will appear on the OCC website. In the meantime its existing card, wallet and transfer programs keep running as usual, which gives the company the luxury of a long review: the operations it wants to consolidate do not stop while the application sits in the queue.