The Office of the Comptroller of the Currency issued its final rule implementing the GENIUS Act on October 21. It is the first final rule from a primary federal stablecoin regulator, and it takes effect on January 18, 2027, the same day as the Act. The OCC received about 328 comments and dropped three contested parts of its proposal.
The GENIUS Act, signed on July 18, 2025, is the US law for payment stablecoins, tokens an issuer must redeem for a fixed amount of money. The OCC proposed its rules on February 25 and published them in the Federal Register on March 2. Comments closed on May 1, and the agency kept reading late letters until July 1. Comptroller Jonathan Gould said the agency is "providing a clear, practical framework for payment stablecoin innovation."
Effective 18 months later unless final rules come first.
Two reserve options, a yield presumption, a seven-day redemption extension.
About 328 letters, late ones read until July 1.
Presumption, maturity limit and automatic extension removed.
Applications and waivers open earlier, date not set.
What changed between the proposal and the final rule
The yield question drew the most comment. The Act bans a permitted issuer from paying interest or yield solely for holding, using or retaining its stablecoin. The proposal added a rebuttable presumption that certain payments through affiliates or related third parties violate that ban. Banks wanted it broadened. Crypto firms wanted it narrowed or removed.
The OCC removed it. The rule text says a presumption could be both overinclusive and underinclusive in a nascent market, and that the rebuttal process would impose burden without a matching benefit. The agency will instead monitor arrangements when it reviews applications and supervises issuers, act where it finds evasion, and propose a clarifying rule once it has enough cases. It adopted no safe harbor for de minimis payments or white-label partners, and no cure period for violations.
Reserves changed too. The proposal offered two options. Option A's safe harbor required 10 percent of reserves in daily liquidity, 30 percent in weekly liquidity, no more than 40 percent at one institution and a weighted average maturity of 20 days or less.
The final rule requires at least 5 percent in demand deposits or in an account at a Federal Reserve Bank, and caps exposure to any one counterparty at 40 percent. Exposures to the US government, to a qualifying custodian and through centrally cleared repos are excluded from the cap. The weekly liquidity test and the maturity limit are gone.
| Provision | March 2 proposal | Final rule |
|---|---|---|
| Yield ban | Rebuttable presumption for certain affiliate and related third-party payments | Presumption removed; case-by-case supervision, action on evasion |
| Daily liquidity | 10 percent of reserves (both options) | 5 percent in demand deposits or at a Federal Reserve Bank |
| Reserve maturity | Weighted average of 20 days or less (Option A safe harbor) | No limit |
| Concentration | 40 percent at any one eligible financial institution | 40 percent per counterparty, US government and custodian exposures excluded |
| Redemption spike | Automatic extension to seven calendar days above 10 percent in 24 hours | Notice to the OCC within 24 hours; issuer may request an extension |
| Standard redemption | Within two business days | Within two business days |
Redemption was the third change. The proposal would have stretched the redemption deadline to seven calendar days automatically once requests passed 10 percent of outstanding value in 24 hours. Commenters said a fixed trigger could start the run it was meant to slow, and the OCC agreed that it could prove pro-cyclical. The final rule keeps the 10 percent threshold only as a reporting line: notice to the supervisory office within 24 hours, with an extension available at the OCC's discretion.
Why the rewards question stays open
The GENIUS ban applies to issuers, not to exchanges or wallets. Cointelegraph reported that the OCC keeps its authority to act against evasion. Bitcoin Magazine, citing Crypto in America, reported that an OCC official declined to say whether existing exchange reward programs comply and said the agency would let the market develop and address cases as they come.
Banks object. The American Bankers Association said the final rule risks undermining Congress's intention to protect local lending and may preserve the status quo for crypto platforms, Crypto Briefing reported. In our reading, the rule moves the fight from the text to the application file. Any exchange arrangement an applicant discloses becomes a supervisory question before January 18, which gives the OCC leverage without a written test.
The rule's own cost analysis shows the scale the agency has in mind. It assumes 22 permitted issuers and $272.3 billion of outstanding stablecoins, with $50 billion issued by OCC-regulated bank affiliates in 2027. It also expects the reserve rules to raise demand for Treasury securities with 93 days or less to maturity, the only Treasuries the Act allows as reserves. Those are modelling assumptions, not commitments.
What to watch
The OCC will accept applications and waiver requests before the effective date, once the Office of Management and Budget approves its forms, and will announce the start in a bulletin. A waiver can cover an applicant for up to 12 months from January 18, 2027. Bulletin 2026-51 already sets out how to file.
- An OCC bulletin opening applications. The first named applicants will show who wants a federal license.
- Companion rules. The Federal Reserve and FDIC have proposals out and Treasury is drafting its own, Bitcoin Magazine reported. Nonbank state issuers above $10 billion must transition to federal oversight under the Act.
- The separate anti-money laundering rule. The OCC and Treasury will handle Bank Secrecy Act and sanctions requirements in another rulemaking.
For how reserves, redemptions and depegs work in practice, see our stablecoin guide. The EU side of the calendar, with its own January 2027 deadline for non-MiCA stablecoins, is in our ESMA report.
