The US agency OCC has become the first federal banking regulator to publish its final rule under the GENIUS Act. Effective January 18, 2027, the rule drops the proposal's presumption against third-party arrangements for stablecoin rewards.
Officially named the Office of the Comptroller of the Currency, the OCC is part of the US Treasury Department. It supervises national banks and federally chartered savings institutions. The GENIUS Act creates a federal framework for payment stablecoins. Issuers must fully back their tokens with US dollars or similarly liquid assets and undergo annual audits. In addition, they may not pay interest. President Trump signed the law in July 2025. The OCC announced its proposed rule in February 2026, and publication in the Federal Register followed in March. In total, the agency received around 328 comments from crypto firms, community banks, trade associations and academics. The newly published final rule creates a new Part 15 in Title 12 of the Code of Federal Regulations. It covers national banks, federal savings associations, federal branches and their subsidiaries. Federally licensed nonbank issuers and foreign issuers under OCC jurisdiction fall under it too.
Subscribe to our newsletter
The best articles of the week, directly delivered into your mailbox.
What the OCC final rule requires of GENIUS Act issuers
The rule covers an issuer's full life cycle. This spans everything from permitted activities, reserve assets and redemption to the revocation of a license. Furthermore, it governs risk management, examinations, reporting and ongoing supervision, along with applications, registrations and a capital and operational backstop. Certain custody activities of OCC-supervised institutions fall under the new standards as well. State-chartered issuers get a path into the federal framework, while foreign issuers are subject to separate supervision. At the same time, the OCC is amending existing rules on capital, prompt corrective action, fees and procedures.
Comptroller Jonathan V. Gould describes a clear, workable framework for innovation in payment stablecoins. In his words, strict standards apply to reserve backing, redemption and risk management. The full-reserve requirement comes from the statute itself. The final rule implements it through its requirements on reserve assets for supervised issuers. Gould places the rule within the digital asset agenda of President Trump and Treasury Secretary Bessent.
The rule deliberately leaves out the Bank Secrecy Act, anti-money laundering (AML) rules and OFAC sanctions. A separate rulemaking with the Treasury Department will cover these areas later. A proposal on the Bank Secrecy Act and money laundering has been in the Federal Register since June 2026. Still, no final rule on it exists yet. Thus, for now the OCC covers the prudential side, not the duties against financial crime. Issuers should therefore expect two sets of rules. Other federal agencies are still working on their parts of the GENIUS implementation.
The presumption against third parties falls away
The final rule leaves the interest ban itself unchanged. Issuers still may not pay interest or yield tied solely to holding, using or retaining a stablecoin. However, the February proposal went further. It originally included a presumption that certain arrangements with affiliates or third parties could be impermissible. As a result, rewards paid out by a partner rather than the issuer itself would also have come under scrutiny.
The final rule no longer contains this presumption. During a press briefing, an OCC official said the proposed text had been an estimate of whether evasion was likely. It did not reflect an understanding of what is still a young market. Instead, the agency will now review each case individually. Where an issuer maintains relationships with third parties, the OCC wants to ensure they do not violate the statutory ban. It can also act against a clear evasion of the law.
Ultimately, the question reflects a conflict between banks and crypto platforms. The law bans interest only for issuers. But it does not stop platforms such as Coinbase from offering rewards to their customers. Banks, by contrast, warn that such programs could drain deposits and weaken community institutions. Notably, the deletion only partly improves legal certainty for platforms. True, the blanket suspicion against partner models no longer applies. However, the OCC official left open whether existing rewards programs comply. Consequently, providers will learn only case by case whether their model counts as evasion.
Waivers give issuers up to twelve months of breathing room
The rule and the law take effect on January 18, 2027. So issuers have had 18 months to prepare since the signing in July 2025. Yet the agency will accept applications only once the Office of Management and Budget (OMB) has approved the application forms. It will announce the start separately. For the transition, the OCC provides a waiver process. Issuers with a substantially complete application pending on or before the effective date can request such an exemption. It lasts no more than twelve months from the effective date. The regulator generally intends to grant waivers to existing issuers operating in the US.
The application process itself follows fixed deadlines. First, the OCC checks within 30 days whether an application is complete. If an issuer submits additional documents, the agency reviews them within 30 days too. If an application still remains incomplete, the OCC returns it no later than 60 days after the first notice. Finally, the agency aims to decide on complete applications within 120 days. Likewise, the OCC has published revised reporting forms.
The GENIUS Act refers to licensed issuers as Permitted Payment Stablecoin Issuers. Anyone issuing without this license on or after the effective date risks penalties. The OCC explicitly cites criminal consequences. Issuers that currently neither operate nor issue in the US, on the other hand, should not expect waivers. The agency expects them to start business only after receiving a license. Hence, without a waiver, they get no transition period from the effective date.
The rewards dispute moves to the CLARITY Act
The final rule answers the rewards question only at the regulatory level. Politically, it remains a core issue of the CLARITY Act. That bill aims to set out a comprehensive market structure for digital assets. Yet the Senate failed to advance it in a procedural vote. Since then, it has stalled. Moreover, the roughly 328 comments on the OCC proposal show how closely both sides followed the process. Some submissions called for a broader presumption, others for a narrower version or its removal.
For issuers and platforms, regulatory clarity is consequently only partial. Reserves, redemption and licensing are binding from January 2027. Until Congress draws a line, the regulator will decide on rewards case by case for now. On the one hand, banks point to deposit outflows and the weakening of small institutions. On the other hand, the crypto industry argues that the GENIUS Act does not ban rewards via platforms. If lawmakers change the legal situation, the OCC plans to adjust its rule.
