Rain files for a national trust bank charter to issue stablecoins under GENIUS Act
The proposed Rain National Trust Bank would custody digital and fiat assets and manage reserves for stablecoin issuers, but would not take deposits or make loans.
Rain, a stablecoin infrastructure company, filed an application Monday with the Office of the Comptroller of the Currency to establish Rain National Trust Bank, a proposed national trust bank headquartered in New York.
If approved, the entity would be an uninsured trust bank rather than a conventional depository institution. Its charter would authorize 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 licensing framework established by the GENIUS Act. The filing is explicit that the bank will not accept deposits, offer consumer accounts, or make commercial loans.
That scope mirrors a path other stablecoin and digital-asset firms have pursued over the past two years: a national trust charter grants a federal legal wrapper and OCC supervision for custody and stablecoin-reserve activity without triggering the capital, deposit-insurance and consumer-protection regime that applies to a full-service bank.
The application is now subject to OCC review and a public comment period, the standard process for new national bank charters, during which the agency and the public can raise objections before any decision is made. Charter applications of this kind have taken anywhere from several months to over a year to resolve in recent cycles, and approval is not guaranteed.
The filing arrives as the GENIUS Act's stablecoin-issuer licensing regime continues to take shape, with licensing set to open in January 2027 and unlicensed issuance barred from July 2028. A national trust charter would position Rain to custody reserves and issue stablecoins under that framework directly, rather than relying solely on state-level trust or money-transmitter licenses, which is the structure most non-bank stablecoin issuers have used to date.