Rain Applies for a National Trust Bank Charter to Custody Stablecoin Reserves
The crypto-linked card company filed with the OCC to create Rain National Trust Bank, which would hold stablecoin reserves and provide digital-asset custody but would not accept deposits or carry FDIC insurance.
NEW YORK — Rain, a company best known for crypto-linked card issuance infrastructure, has filed an application with the Office of the Comptroller of the Currency to charter Rain National Trust Bank, a proposed New York-based national trust bank. If approved, RNTB would operate as a separately capitalized subsidiary providing fiduciary custody of digital and fiat assets, reserve management for stablecoin issuers, and the issuance and redemption of U.S. dollar-backed stablecoins under the GENIUS Act framework Congress enacted earlier this year.
The application is explicit about what the proposed bank would not do: it would not accept deposits, offer consumer accounts, or make commercial loans, and it would not carry FDIC insurance. That is a narrower charter than a conventional bank, structured around the specific activities the GENIUS Act contemplates for stablecoin issuers and custodians rather than general-purpose banking.
Rain's filing is the latest in a wave of similar applications this year, following conditional OCC approvals for Bastion and Agora and an earlier filing from Protego Holdings Corporation, all seeking the same category of charter to consolidate stablecoin custody and reserve functions under direct federal supervision rather than a patchwork of state money-transmitter licenses. The pattern reflects a broader shift: companies that built stablecoin infrastructure under state-by-state licensing are now converging on a single federal trust charter as the GENIUS Act's compliance framework takes effect.
That convergence is happening against an unresolved legal backdrop. The Independent Community Bankers of America sued the OCC in October, arguing the agency has exceeded its authority under the National Bank Act by granting national trust charters to crypto firms, and is seeking to vacate both the OCC's March rule and Protego's conditional approval specifically. Rain's application does not depend on that litigation resolving in any particular direction, but the outcome will shape how much certainty any newly chartered stablecoin trust bank, including RNTB if approved, can have about the durability of its charter.
For a company evaluating whether to trust a stablecoin issuer with custody of the reserves backing it, the distinction between a trust charter and deposit insurance is the detail worth holding onto. RNTB, as proposed, would be subject to OCC supervision and the GENIUS Act's reserve and disclosure requirements, but a dollar held in custody there would not carry the same federal backstop as a dollar in an FDIC-insured deposit account — a difference that matters most precisely when something goes wrong.