Rain has applied to the OCC to establish Rain National Trust Bank (RNTB), a proposed subsidiary for stablecoin custody, reserves, and issuance.
If approved, the US-based entity would operate as a separately capitalised subsidiary of Rain. It would bring custody, reserve management, and stablecoin issuance and redemption under a single federal supervisory framework.
Rain's partners operate stablecoin card, wallet, and money movement programmes for millions of end users. The assets behind those programmes are currently spread across state licences, third-party custodians, and third-party stablecoin issuers. A national trust bank would allow Rain to provide fiduciary custody subject to OCC supervision and examination, and to issue and redeem stablecoins itself. According to Farooq Malik, CEO and co-founder of Rain, institutions building on the platform want the assets underpinning their programmes held by a fiduciary accountable to a federal regulator. The official added that Rain itself will remain a payments platform, with RNTB set up as a distinct subsidiary.
Three proposed lines of business
RNTB would serve institutional clients in the digital asset payments ecosystem through three activities. The first is custody, under which the trust bank would safeguard approved digital and fiat assets as a fiduciary, keeping client holdings segregated from its own assets. The second is reserve management, covering the holding and administration of reserves for permitted stablecoin issuers under the GENIUS Act. The third is issuance and redemption, with RNTB acting as issuer of record for US dollar-backed stablecoins in line with the same legislation.
Limits of the proposed charter
As an uninsured national trust bank, RNTB would not accept deposits, make commercial loans, or offer consumer accounts, and it would not be FDIC insured. Assets held for clients would be custody assets belonging to identified owners rather than liabilities of the bank. Reserves backing any stablecoin RNTB issues would not be pledged, lent, or reused.
Rain's existing structure is unaffected. The company continues to operate as a stablecoin payments platform and a Visa and Mastercard Principal Member through its other subsidiaries, and its card, wallet, and money movement programmes and partnerships will continue as they are.
The company describes RNTB as a multi-year initiative that would add a federally supervised option alongside the infrastructure its partners currently use, consolidating functions now handled by several state-licenced and third-party providers.
Leadership and regulatory process
If the application is approved, Rain proposed former Square Financial Services CFO Brandon Soto as President and CEO of RNTB. Soto noted that a trust bank's core task is knowing what it holds and for whom. Drawing on 20 years of engagement with bank examiners, he pointed to clear ownership, daily reconciliation, strong controls, and adequate capital as priorities from the outset.
The application is subject to OCC review and approval, including a public comment period, and follows the regulator's own timeline. RNTB can begin operations only after receiving all required approvals.
