Rain Applies to OCC for National Trust Bank Charter

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Rain has filed an application with the U.S. Office of the Comptroller of the Currency (OCC) for a national trust bank charter under the proposed name Rain National Trust Bank (RNTB), headquartered in New York. This move supports efforts to enhance CFT compliance in liquidity and crypto markets. RNTB aims to centralize custody, reserve management, and stablecoin issuance and redemption under federal oversight. Brandon Soto will serve as CEO and President of the proposed bank.
CoinDesk reports:

New York, October 5 /PRNewswire/ — Rain, an enterprise infrastructure company for stablecoin payments, today announced it has submitted an application to the U.S. Office of the Comptroller of the Currency (OCC) to establish Rain National Trust Bank (RNTB), a proposed national trust bank headquartered in New York. If approved, RNTB will bring the custody, reserve management, and stablecoin issuance and redemption functions behind Rain’s partner program under a unified federal regulatory framework. Rain also announced that Brandon Soto will serve as the proposed President and Chief Executive Officer of RNTB.

Rain’s partners operate stablecoin cards, wallets, and funds transfer services serving millions of end users. Today, the assets behind these initiatives are dispersed across state licenses, third-party custodians, and third-party stablecoin issuers. A national trust bank will enable Rain to scale its services under the supervision and examination of the OCC, including trusted custody of assets and the issuance and redemption of stablecoins.

Farooq Malik, Co-founder and CEO of Rain, said: "Institutions building businesses on Rain want the assets behind their projects held by a trustee accountable to federal regulators. Rain National Trust Bank is how we plan to meet this expectation. Rain remains a payment platform. The proposed trust bank will be an independent subsidiary that holds customer assets in a fiduciary capacity and is subject to OCC examinations."

What will Rain National Trust Bank do?

If approved, RNTB will serve institutional clients in the digital asset payments ecosystem through three business lines:

  • Custody: Holding approved digital and fiat assets in a fiduciary capacity, with client assets segregated from the proposed bank’s own assets.
  • Reserve Management: Hold and manage reserves for approved stablecoin issuers under the GENIUS Act.
  • Issuance and Redemption: Issuing dollar-backed stablecoins as a registered issuer under the GENIUS Act.

Rain National Trust Bank will not

If approved, as an uninsured national trust bank, RNTB will not accept deposits or extend commercial loans. Assets held by customers at RNTB will be custodial assets held for identified owners, not bank liabilities; reserves backing any stablecoins issued by RNTB will not be pledged, lent, or reused. RNTB will not offer consumer accounts. Rain is not a bank and will continue to operate as a stablecoin payment platform and a primary member of Visa and Mastercard through its other subsidiaries; RNTB will be a separately capitalized subsidiary supervised and examined by the OCC.

Management

Brandon Soto will serve as the proposed President and Chief Executive Officer of RNTB following OCC approval. Soto most recently served as Executive Vice President and Chief Financial Officer of Coastal Financial Corporation. Prior to that, he was Chief Financial Officer at Square Financial Services, Inc., an industrial bank chartered by Utah under Block, where he helped prepare and advance the bank’s charter application for approval by the FDIC and the Utah Department of Financial Institutions, and was responsible for finance, funding, and capital management. Earlier, he served as Chief Financial Officer and Chief Administrative Officer at Green Dot Bank.

Soto said: “The first job of a trust bank is simple: know what you hold, know for whom you hold it, and ensure security. Having worked with bank examiners for twenty years, the best answer is always, ‘Here’s the reconciliation.’ This is precisely the discipline we must embed from day one in the proposed national trust bank: clear ownership, daily reconciliation, strict controls, and appropriate levels of capital.”

What happens next?

This application is subject to review and approval by the OCC, including a public comment period. The public portion of the application will be available on the OCC’s website at occ.gov. Rain’s management and the sponsors of RNTB recognize the responsibilities associated with applying for a national trust bank charter and will work closely with the OCC throughout the process.

Rain collaborated with Paul Hastings during the application process.

Frequently Asked Questions

Question: What is Rain National Trust Bank?
Answer: Rain National Trust Bank (RNTB) is a proposed national trust bank. Rain has submitted an application to the U.S. Office of the Comptroller of the Currency (OCC) to establish this institution. If approved, RNTB will be a separately capitalized subsidiary of Rain, headquartered in New York, subject to OCC supervision and examination, and limited to the business of an uninsured trust bank, including: fiduciary custody of digital assets and U.S. dollars, managing reserves for approved stablecoin issuers, and issuing and redeeming U.S. dollar-backed stablecoins for institutional clients. RNTB has not yet been approved and will not begin operations until it receives all necessary OCC approvals.

Question: Will Rain become a bank?
Answer: Rain is applying to establish a separate, limited-purpose trust bank subsidiary. Rain itself will remain a stablecoin payment platform and a primary member of Visa and Mastercard—this will not change. Rain National Trust Bank will be a separately capitalized subsidiary of Rain with a limited purpose: to hold customer assets as trustee, manage stablecoin reserves, and issue and redeem stablecoins, all under OCC supervision. Rain National Trust Bank will be an uninsured trust bank that will not accept deposits or make commercial loans.

Question: Will Rain National Trust Bank have FDIC insurance?
Answer: No. Rain National Trust Bank will not accept deposits nor be FDIC-insured. Assets held by RNTB for its clients will be custodial assets held for the benefit of identified owners, segregated from RNTB’s own assets, and not considered liabilities of RNTB.

Question: What will Rain National Trust Bank do?
Answer: If approved, Rain National Trust Bank will operate three business lines for institutional clients. Custody: Safely hold approved digital and fiat assets as a trustee. Reserve Management: Hold and manage reserves for approved stablecoin issuers under the GENIUS Act. Issuance and Redemption: Issue USD-backed stablecoins as a registered issuer.

Question: Who is the proposed President and CEO of Rain National Trust Bank?
Answer: Brandon Soto is the nominated President and Chief Executive Officer of Rain National Trust Bank. He most recently served as Executive Vice President and Chief Financial Officer of Coastal Financial Corporation, and prior to that, as Chief Financial Officer of Square Financial Services, Inc.—an industrial bank chartered by the state of Utah under Block—where he assisted in preparing the bank’s charter application and oversaw finance, funding, and capital management. Earlier, he served as Chief Financial Officer and Chief Administrative Officer of Green Dot Bank. He is a certified public accountant.

Question: Will this change Rain’s card business or partnerships?
No. Rain’s cards, wallets, and funds movement services will continue operating as they do today, and Rain will continue working with its existing partners. Rain National Trust Bank is a multi-year initiative that, if approved, would add a federally regulated option for custody, reserve management, and stablecoin issuance and redemption, beyond the infrastructure Rain and its partners use today.

Question: When will the OCC decide on Rain National Trust Bank’s application?
Answer: OCC's review follows its own process and timeline, which includes a public comment period. The public portion of the application will be posted on the OCC website in the coming days. Rain National Trust Bank can only begin operations after obtaining all necessary approvals.

About Rain

Rain is a global stablecoin payments platform for enterprises, neobanks, platforms, developers, and AI agents. Its technology enables partners to quickly and compliantly transfer, store, and use stablecoins through global payment cards, rewards, fiat on/off-ramps, stablecoin and fiat wallets, and cross-border channels. As a direct member of Visa and Mastercard, Rain-issued cards are accepted at over 175 million merchant locations in more than 200 countries and regions. Built natively for stablecoins and trusted by over 100 institutions worldwide, Rain provides secure, scalable infrastructure that enables funds to move freely and instantly across borders. Learn more at https://www.rain.xyz/.

Media contact: [email protected]

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