Rain asks the OCC to create a trust bank to custody assets and operate with stablecoins

Rain applied to the United States Office of the Comptroller of the Currency (OCC) for authorization to establish Rain National Trust Bank, a national trust entity proposed to be based in New York. Filed on October 5, 2026, the application proposes offering institutional clients services involving digital assets, dollars, and stablecoins. The OCC has not yet approved the application.

What activities Rain proposes

If authorized, the bank could custody digital assets and dollars, manage reserves for authorized stablecoin issuers, and issue and redeem dollar-backed tokens, according to information about the application. Rain thus proposes bringing together under one trust entity services that may currently depend on different providers.

The project does not contemplate accepting customer deposits, offering consumer accounts, or making commercial loans. It would also not include deposit insurance coverage from the Federal Deposit Insurance Corporation (FDIC). Rain has proposed keeping assets custodied for customers separate from the bank’s own assets; this segregation is not equivalent to federal insurance and does not guarantee the value of a stablecoin.

The application proposes Brandon Soto, former chief financial officer of Square Financial Services, as the entity’s president and chief executive officer. His appointment is also subject to OCC review.

ICBA challenges the licensing framework

The initiative comes just days after the Independent Community Bankers of America (ICBA) sued the OCC. The association is challenging an agency rule on granting licenses to national trust banks and a 2021 regulatory interpretation. According to the ICBA, this framework allows entities with crypto activities to obtain national licenses without assuming the same obligations as traditional banks.

The organization also argues that the designation “national bank” could lead some consumers to believe their assets are federally insured. These points are ICBA arguments, not judicial findings. The lawsuit does not by itself invalidate the rules or determine the outcome of Rain’s application.

The dispute matters to companies seeking to operate custody or stablecoin services under federal supervision, but its effect on Rain’s application will depend on the OCC’s decisions and how the court proceedings progress. Rain filed its application three days after the lawsuit; the timing does not show that the ICBA’s action was specifically directed at the company.

Authorization pending, not an approved operation

For Rain, a federal license would allow the described activities to be carried out through a trust entity subject to OCC supervision. For its potential institutional clients, the project aims to integrate custody and reserve management within a single structure. However, until the regulator rules on the application, these services remain part of a proposal, not an authorized bank.

The potential license would also not automatically make the stablecoins served by the entity insured deposits or guarantee that they maintain their peg to the dollar. The announced scope is fiduciary and infrastructure-related; it does not include the deposit-taking and lending functions associated with traditional commercial banking.