Stablecoin payments company Rain has filed an application with the Office of the Comptroller of the Currency to establish a national trust bank, joining a growing queue of crypto firms trying to bring custody and stablecoin operations under federal supervision. The move reflects a broader push by stablecoin businesses to own the custody and reserve plumbing behind dollar-backed tokens rather than depend on partner banks. Rain National Trust Bank, the proposed New York subsidiary, would provide fiduciary custody of digital assets and U.S. dollars, manage reserves for permitted stablecoin issuers, and issue and redeem dollar-backed stablecoins for institutional clients.
The filing, disclosed in the company announcement on Oct. 5 and reported by CoinDesk on Oct. 7, makes Rain the twelfth crypto firm seeking an OCC trust charter. The application remains subject to OCC approval and a public-comment period, so the bank can only begin operating after the regulator signs off.
What the Charter Would Let Rain Do
As an uninsured national trust bank, Rain National Trust Bank would not accept deposits, make commercial loans, offer consumer accounts, or carry FDIC insurance. Its role is narrower: it would act as a fiduciary custodian for client assets, which Rain said would be segregated from the bank’s own holdings, and it would handle the reserve management and stablecoin issuance and redemption that Rain’s partner programs currently route through third-party custodians and issuers across various state licenses.
Rain itself would remain a stablecoin payments platform and a Visa and Mastercard principal member, with the trust bank operating as a separately capitalized subsidiary supervised and examined by the OCC. The company said the structure would bring those custody, reserve, and issuance functions under a single federal supervisory framework rather than the patchwork it relies on today. Rain worked with law firm Paul Hastings on the application.
Why Crypto Firms Are Chasing Trust Bank Charters
The filing extends a rush for limited-purpose national trust charters that began picking up late last year. Circle, Ripple, BitGo and Fidelity were among five crypto firms to receive initial OCC approvals in December, and Circle secured final approval for its own federal trust bank in New York in late July. For a stablecoin business, a charter means relying less on third parties to hold customer assets, administer reserves, and process issuance and redemptions, while gaining the credibility of federal examination. The goal in each case is the same: keep more of the stablecoin stack in-house while trading a patchwork of state money-transmitter licenses for one federal charter.
A Lawsuit That Could Slow the Rush
The pathway is also under direct legal challenge. The Independent Community Bankers of America sued the OCC last week, arguing the agency lacks authority to grant national trust charters to crypto firms that do not provide traditional banking services. The trade group contends the structure hands crypto companies banking privileges without the same obligations lenders face.
That dispute leaves the timing of Rain’s charter uncertain even as applications keep arriving, since an adverse ruling could stall every pending crypto trust application rather than just Rain’s. The public portion of the filing is expected to appear on the OCC’s website in the coming days, opening a comment period that will show how much opposition the application draws.
