Rain's application proposes a structure where assets held for clients are segregated from the bank's own assets, addressing a key custody concern. However, the plan would also allow stablecoin reserves held by the proposed bank to be lent, pledged or reused — a practice that may attract regulatory scrutiny.
The charter route has drawn opposition from traditional banks across the United States. Last week, the Independent Community Bankers of America (ICBA) sued the OCC, arguing the agency lacks authority to grant national trust charters to crypto firms that do not offer traditional banking services. The ICBA contends the structure gives crypto companies banking privileges without the same obligations that lenders face.
Rain's application now enters a public comment period and awaits an OCC decision.