Rain Applies for OCC National Trust Bank Charter for Stablecoin Services

What Rain is proposing

Rain, which describes itself as enterprise-grade infrastructure for stablecoin payments, said the proposed bank would serve institutional clients in the digital asset payment ecosystem. According to the company, Rain's partners run stablecoin card, wallet and money movement programs for millions of end users. The assets behind those programs currently sit across state licenses, third-party custodians and third-party stablecoin issuers.

If the OCC approves the application, RNTB would operate three lines of business:

• Custody: safeguarding approved digital and fiat assets as a fiduciary, with client assets segregated from the bank's own assets.
• Reserve management: holding and administering reserves for permitted stablecoin issuers under the GENIUS Act.
• Issuance and redemption: issuing US dollar-backed stablecoins as issuer of record in accordance with the GENIUS Act.

Farooq Malik, CEO and co-founder of Rain, said institutions building on Rain "want the assets behind their programs held by a fiduciary that answers to a federal regulator."

Limits of the proposed bank

Rain stressed that RNTB would be an uninsured, limited-purpose institution. It would not accept deposits, would not make commercial loans and would not offer consumer accounts. It would not be FDIC insured. Assets it holds for clients would be custody assets held for identified owners, not liabilities of the bank. According to Rain, the reserves backing any stablecoin RNTB issues would not be pledged, lent or reused.

Rain itself is not becoming a bank. The company said it will remain a stablecoin payments platform and a Visa and Mastercard Principal Member through its other subsidiaries. RNTB would be a separately capitalized subsidiary supervised and examined by the OCC. Rain also said its card, wallet and money movement programs continue as they operate today, and that it continues to work with existing partners. It described the trust bank as a multi-year initiative that would add a federally supervised option alongside the infrastructure in use today.

Leadership and next steps

Brandon Soto is named as the proposed President and Chief Executive Officer of RNTB, subject to OCC review. He was most recently Executive Vice President and Chief Financial Officer of Coastal Financial Corporation. Before that he was Chief Financial Officer of Square Financial Services, Inc., Block's Utah-chartered industrial bank, where, according to Rain, he helped prepare the charter application approved by the FDIC and the Utah Department of Financial Institutions. He also served as Chief Financial Officer and Chief Administrative Officer of Green Dot Bank.

"A trust bank's first job is simple. Know what you hold, know who you hold it for, and keep it safe," Soto said, according to the announcement.

The application is subject to OCC review and approval, including a public comment period. The public portion will be available on the OCC's website at occ.gov. RNTB can begin operations only after receiving all required approvals, and the OCC's review follows its own process and timeline. Rain said it worked with Paul Hastings in preparing the application.

What it means for the market

For Rain's partners, the proposal points to a possible path to hold client assets and reserves, and to issue and redeem stablecoins, under one federal supervisory framework rather than across several state licenses and third-party providers. Nothing changes immediately: the bank has not been approved, and the timing of any decision rests with the OCC.