Rain National Trust Bank files an OCC charter

Rain National Trust Bank is a filing for a fiduciary wrapper, not a deposit licence. On October 5, 2026, Rain asked the Office of the Comptroller of the Currency (OCC) to charter a New York national trust bank that would custody assets and issue US dollar stablecoins without taking deposits or making loans. Banking Dive on October 6 placed the company in New York City, three days after community banks sued the OCC over non-fiduciary trust charters.

Rain says Rain National Trust Bank would hold client assets as a fiduciary, not as liabilities of the bank, and would not lend the reserves behind a coin it issues. Rain says there is no Federal Deposit Insurance Corporation (FDIC) cover. The Independent Community Bankers of America (ICBA), in its October 2, 2026 suit, treats that missing cover as the defect rather than the design.

Three lines, none of them deposits

Rain's October 5 announcement, also on PR Newswire, says Rain National Trust Bank would be a separately capitalised subsidiary under OCC examination. If approved, institutional clients would get segregated fiduciary custody of digital assets and US dollars, reserve administration for permitted stablecoin issuers under the GENIUS Act, and issuance and redemption of US dollar stablecoins as issuer of record. Issued-coin reserves would not be pledged, lent, or reused. No consumer accounts, deposits, or loans.

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The parent stays a payments platform. Visa and Mastercard principal membership, Rain says, sits in other subsidiaries, and live programmes do not move. Assets still sit with state licences and outside custodians and issuers. An August report on Rain's agentic payments alliance was silent on who bears a loss, and this filing still is.

"The institutions building on Rain want the assets behind their programs held by a fiduciary that answers to a federal regulator," Farooq Malik, chief executive and co-founder of Rain, said in that release. "… Rain remains a payments platform. The proposed trust bank will be a separate subsidiary that holds client assets in custody, as a fiduciary and subject to OCC examination."

Not a repeat of Square

Brandon Soto is the proposed president and chief executive, subject to OCC review. Rain says he was most recently executive vice president and chief financial officer of Coastal Financial Corporation, before that chief financial officer of Square Financial Services, Block's Utah industrial bank, where he helped prepare the charter application the FDIC and the Utah Department of Financial Institutions approved, and earlier chief financial officer and chief administrative officer of Green Dot Bank. The FDIC on March 18, 2020 approved deposit insurance so Square Financial Services could lend from Salt Lake City. This trust would not take deposits.

"A trust bank's first job is simple. Know what you hold, know who you hold it for, and keep it safe," Soto said. "I have sat across from bank examiners for twenty years, and the best answer you can give is, 'Here's the reconciliation.' That is the discipline we are building into the proposed national trust bank from day one."

No capital figure is stated. Rain says the review includes public comment and that the public portion will be posted on occ.gov, where new charters are noticed. The bank cannot open before approval.

The suit is three days older

Rebeca Romero Rainey, president and chief executive of the ICBA, said on October 2: "The OCC's decision to allow companies to obtain national trust bank charters to conduct substantial non-fiduciary activities exceeds the authority Congress granted the agency." The District of Columbia case targets the March 2, 2026 rule on Interpretive Letter No. 1176 and seeks to vacate Protego Holdings' February 2026 conditional charter. National Bank Act section 27(a) says a national bank is not illegally constituted solely because the comptroller limits it to "a trust company and activities related thereto." PYMNTS reported on October 7 that the complaint counts 21 approved or conditionally approved national trust charters during the Trump administration, at least 13 involving cryptocurrency firms.

No card programme clears on this notice. Approval would name the issuer of record and the reserve holder. SoFiUSD already settles on SoFi Bank's Mastercard rail. Builders Bank is a separate uninsured trust bid for bitcoin custody, and a Fed stablecoin-capital docket prices the exposure on other books.

A win for the ICBA puts trust-charter issuance inside the case. A loss still leaves the multi-year build Rain describes, unstated capital, and assets held elsewhere. Neither path is deposit insurance. The public file has to match the three lines.

This article is informational analysis only and is not financial, investment, or trading advice. Cryptocurrencies are highly volatile and can lose substantial value rapidly. Past performance and historical patterns do not guarantee future results. Do your own research and consult a regulated financial adviser before making any investment decision.