Rain is seeking a national trust bank charter to bypass third-party banks

Rain has submitted an application to the Office of the Comptroller of the Currency seeking a limited-purpose national trust bank charter for a proposed New York subsidiary called Rain National Trust bank. The firm says the bank would provide fiduciary custody of digital assets and U.S. dollars, take responsibility for stablecoin reserve management for permitted issuers, and handle issuance and redemption of dollar-backed stablecoins for institutional clients. Under the proposal, the trust bank would not operate like a traditional commercial bank: it would not accept consumer deposits, offer consumer accounts, or make commercial loans, and it would not carry FDIC insurance. Rain has stated that assets held on behalf of clients would be segregated from the bank’s own holdings, and that stablecoin reserves held by the proposed bank could be lent, pledged or reused. Rain’s filing joins a growing group of crypto companies pursuing OCC trust charters to bring custody and stablecoin operations under federal oversight. Earlier applicants and approvals in this wave include firms such as Circle, Ripple, BitGo and Fidelity, with Circle receiving final OCC approval to operate a federal trust bank in New York in late July. The OCC charter path has prompted pushback from parts of the traditional banking sector. The Independent Community Bankers of America recently sued the OCC, contending the agency lacks authority to grant national trust charters to crypto firms that do not provide conventional banking services; the ICBA argues the structure affords crypto companies certain banking powers without subjecting them to the same obligations as lenders. Rain’s application remains pending and will proceed through the OCC’s approval process and a public-comment period.