Rain Files Application With the OCC to Establish Rain National Trust Bank

Proposed national trust bank will bring custody, stablecoin reserve management, and stablecoin issuance and redemption for the payments ecosystem under federal supervision

Former Square Financial Services CFO Brandon Soto named proposed President and CEO

• Rain has filed an application with the Office of the Comptroller of the Currency (OCC) to establish Rain National Trust Bank (RNTB), a proposed national trust bank headquartered in New York.

• If approved, Rain National Trust Bank will provide fiduciary custody of digital assets and US dollars, reserve management for permitted stablecoin issuers, and issuance and redemption of US dollar-backed stablecoins for institutional clients.

• Rain National Trust Bank will not accept deposits, offer consumer accounts, or make commercial loans.

• Brandon Soto, former Chief Financial Officer of Square Financial Services and most recently Chief Financial Officer of Coastal Financial Corporation, will serve as the proposed President and CEO of Rain National Trust Bank.

Rain, the enterprise-grade infrastructure for stablecoin payments, announced that it has filed an application with the Office of the Comptroller of the Currency (OCC) to establish Rain National Trust Bank (RNTB), a proposed national trust bank headquartered in New York. If approved, RNTB will bring the custody, reserve management, and stablecoin issuance and redemption functions behind Rain partners’ programs under a single federal supervisory framework. Rain also announced that Brandon Soto will serve as RNTB’s proposed President and Chief Executive Officer.

Rain’s partners run stablecoin card, wallet, and money movement programs for millions of end users. Today the assets behind those programs sit across state licenses, third-party custodians, and third-party stablecoin issuers. A national trust bank will allow Rain to expand its offerings to include fiduciary custody of assets under OCC supervision and examination, and to issue and redeem stablecoins.

“The institutions building on Rain want the assets behind their programs held by a fiduciary that answers to a federal regulator,” said Farooq Malik, CEO and co-founder of Rain. “Rain National Trust Bank is how we plan to meet that expectation. Rain remains a payments platform. The proposed trust bank will be a separate subsidiary that holds client assets in custody, as a fiduciary and subject to OCC examination.”

What Rain National Trust Bank will do

If approved, RNTB will serve institutional clients in the digital asset payment ecosystem through three lines of business:

• Custody: Safeguard approved digital and fiat assets as a fiduciary, with client assets segregated from the proposed bank’s own assets.
• Reserve management: Hold and administer reserves for permitted stablecoin issuers under the GENIUS Act.
• Issuance and redemption: Issue US dollar-backed stablecoins as issuer of record in accordance with the GENIUS Act.

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What Rain National Trust Bank will not do

If approved, as an uninsured national trust bank, RNTB will not accept deposits and will not make commercial loans. Assets held by RNTB for clients will be custody assets held for identified owners, not liabilities of the bank, and the reserves backing any stablecoin RNTB issues will not be pledged, lent, or reused. RNTB will not offer consumer accounts. Rain is not a bank and will remain a stablecoin payments platform and a Visa and Mastercard Principal Member through its other subsidiaries; RNTB will be a separately capitalized subsidiary supervised and examined by the OCC.

Leadership

Brandon Soto will serve as proposed President and Chief Executive Officer of RNTB, subject to OCC review. Soto was most recently Executive Vice President and Chief Financial Officer of Coastal Financial Corporation. Before that he was Chief Financial Officer of Square Financial Services, Inc., Block’s Utah-chartered industrial bank, where he helped prepare the charter application approved by the FDIC and the Utah Department of Financial Institutions and led finance, treasury, and capital management. Earlier he served as Chief Financial Officer and Chief Administrative Officer of Green Dot Bank.

“A trust bank’s first job is simple. Know what you hold, know who you hold it for, and keep it safe,” said Soto. “I have sat across from bank examiners for twenty years, and the best answer you can give is, ‘Here’s the reconciliation.’ That is the discipline we are building into the proposed national trust bank from day one. Clear ownership, daily reconciliation, strong controls, and the right level of capital.”

What happens next

The application is subject to OCC review and approval, including a public comment period. The public portion of the application will be available on the OCC’s website at occ.gov. Rain leadership and RNTB’s organizers recognize the responsibility that comes with seeking a national trust bank charter and will work diligently with the OCC throughout the process.

Rain worked with Paul Hastings in preparing the application.