OCC finalizes GENIUS Act rules for payment-stablecoin issuers

The Office of the Comptroller of the Currency issued a final rule on October 21 implementing its portion of the federal GENIUS Act, converting a February proposal into binding standards for payment-stablecoin issuers under the agency’s jurisdiction.

The rule takes effect January 18, 2027. It covers national banks and federal savings associations and their subsidiaries, federally qualified nonbank issuers, certain state-qualified issuers subject to OCC authority, and foreign payment-stablecoin issuers. It also addresses some custody activities by OCC-supervised entities. The action matters because it supplies a finished federal framework for reserves, redemption, risk management, reporting, supervision and licensing, but it does not complete every agency’s implementation of the law.

Reserves must cover issuance at all times

The final text requires identifiable reserve assets whose fair value equals or exceeds the value of outstanding stablecoins at all times. Eligible assets include U.S. currency, demand deposits, Treasury securities with no more than 93 days remaining to maturity, qualifying repurchase agreements and qualifying government money-market funds. Depending on a portfolio’s interest-rate and liquidity risk, an issuer may need a reserve buffer above one-to-one backing; the OCC did not impose one universal buffer percentage.

That qualification is important. “One-to-one” is a minimum coverage requirement, not a promise that every permitted reserve asset is cash or carries no market, operational or counterparty risk. The rule requires issuers to manage concentration and liquidity so assets can support redemption even under stress.

The OCC said it received approximately 328 comments on the proposal. Its final framework adds public and confidential reporting, independent accounting review and supervisory access, while allowing the agency to tailor capital and operational-backstop requirements to an issuer’s business model and risk profile.

Redemption gets a two-business-day ceiling

An issuer’s published redemption policy generally must provide for completing a redemption no later than two business days after the request. Under the rule, redemption is complete when the issuer has processed and initiated the outgoing transfer of monetary value, or credited the customer’s account when requested.

The standard is an outer limit, not a guarantee that every holder will receive bank cash instantly. Customer-identification checks, lawful orders and permitted restrictions can affect the process. The rule also distinguishes payment stablecoins from bank deposits: GENIUS Act payment stablecoins do not become federally insured deposits merely because an OCC-regulated entity issues or holds them.

Rewards remain a facts-and-circumstances question

The statute bars issuers from paying interest or yield solely for holding, using or retaining a payment stablecoin. The proposal would have created a rebuttable presumption for some payments routed through affiliates or related third parties. The final rule removed that presumption and declined to define “interest” or “yield” exhaustively.

That does not authorize every rewards program. The OCC said labels do not control when a payment is economically interest or yield, leaving particular arrangements to statutory interpretation and case-specific supervision. Platforms and issuers therefore still face uncertainty around how indirect incentives will be treated.

The framework is final, but implementation is incomplete

The October 21 action is a final OCC rule, not an issuer approval or evidence that new stablecoins have launched. The agency says it is not yet accepting issuer applications or waiver requests; intake will begin after the Office of Management and Budget approves the related information collection.

Important compliance work also remains separate. Bank Secrecy Act, anti-money-laundering and sanctions provisions are being handled through another rulemaking coordinated with Treasury. Other federal and state regulators retain their own responsibilities under the statute.

The verified change is narrower than a complete national rollout: entities within the OCC’s perimeter now have final operating rules and an effective date. Actual market access will still depend on applications, approvals, other regulators’ rules and each issuer’s demonstrated compliance.