The Office of the Comptroller of the Currency has finalized its main rule for implementing the GENIUS Act, moving the United States closer to a federal operating framework for payment stablecoins. Published on October 21, the rule sets requirements for issuers under the banking regulator's jurisdiction and for certain custody activities at OCC-supervised institutions. Both the rule and the statute are due to take effect on January 18, 2027.

A rule for reserves, redemption and supervision

The framework is broad rather than limited to the assets backing a token. It establishes standards for permitted activities, reserve assets, redemption, risk management, audits, reporting, custody, applications, supervision of foreign issuers, capital and an operational backstop. It also updates other OCC regulations covering capital adequacy, corrective action, assessments and enforcement procedure. The agency said it received hundreds of comments from crypto companies, community banks, trade groups and academics after proposing the rule in February.

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Entities potentially covered include subsidiaries of national banks and federal savings associations, federally approved nonbank issuers, some state-qualified issuers subject to OCC authority, and foreign payment stablecoin issuers serving the U.S. market. The GENIUS Act generally bars other parties from issuing payment stablecoins in the United States once it becomes effective. That makes regulatory approval, not only technical readiness or reserve funding, a central requirement for companies planning to operate after the January deadline.

Applications are not open yet

The OCC has not announced when it will begin accepting applications and waiver requests. Its guidance says the opening depends on final approval from the Office of Management and Budget for the relevant information collection. Once submissions begin, the regulator plans to notify an applicant within 30 days whether an application is substantially complete and to act no later than 120 days after making that determination. Those timelines do not guarantee approval.

Existing U.S. issuers face a transition problem because the statute requires prior approval from January 18 but does not provide an automatic implementation period. An issuer with a substantially complete application pending by that date may request a waiver, potentially lasting up to 12 months. The OCC said it generally expects to grant prior-approval waivers to existing operators unless its review finds a stronger reason to deny one. Other requirements will still be evaluated separately.

Important details remain outside this rule

The final regulation does not complete every part of the federal stablecoin framework. Bank Secrecy Act, anti-money-laundering and Office of Foreign Assets Control sanctions provisions will be handled in a separate rulemaking coordinated with the Treasury Department. The OCC will also continue coordinating with other regulators implementing the law. For issuers, banks and custodians, that means the October rule clarifies a large part of the compliance architecture but not the entire operating perimeter.

The final text also leaves room for case-by-case enforcement around stablecoin rewards. The Block reported that the OCC removed a proposed presumption targeting certain issuer relationships with third parties, while retaining authority to pursue arrangements it considers an evasion of the statutory ban on issuers paying interest directly. Market participants will therefore be watching application guidance, the separate financial-crime rules and early supervisory decisions. The immediate change is certainty about the main OCC standards; the practical test begins when applications open and examiners apply them.

Sources

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