The Office of the Comptroller of the Currency has finalized regulations implementing major portions of the GENIUS Act for payment stablecoin issuers under its jurisdiction. According to the final rule published in the Federal Register, the regulations take effect on January 18, 2027, alongside the statutory effective date of the GENIUS Act. The framework covers reserves, redemption, risk management, capital, custody, supervision and issuer authorization.
The rule applies to federal qualified payment stablecoin issuers, relevant subsidiaries of national banks and federal savings associations, foreign issuers under OCC supervision and certain state-qualified issuers subject to OCC authority. It establishes the operating framework for OCC-supervised stablecoins without completing every federal rule required under the law. BSA, anti-money-laundering and sanctions requirements remain on a separate rulemaking track coordinated with the Treasury Department.
Reserve Rules Become More Flexible
The final framework is less prescriptive than the February proposal in several areas. Issuers must maintain reserve assets at least equal to outstanding stablecoin issuance at all times and demonstrate that those assets can support timely redemptions under normal and stressed conditions. Redemption periods generally cannot exceed two business days, creating an operational liquidity requirement even after the OCC dropped some proposed portfolio constraints.
The OCC removed the proposed weekly liquidity requirement and the 20-day weighted-average-maturity ceiling, but retained a minimum daily-liquidity threshold. At least 5% of reserve assets must remain in demand deposits, equivalent immediately withdrawable accounts or balances at a Federal Reserve Bank, while exposure to a single counterparty is generally capped at 40%. These rules give issuers greater flexibility to use qualifying reserve instruments, including structures similar to the government money-market funds being developed for stablecoin reserves.
Reserve management also becomes more flexible operationally. The proposal would have allowed surplus reserve withdrawals only once per month, following publication of the composition report. The final rule permits excess reserves to be withdrawn at any time after appropriate due diligence confirms that remaining reserves will still cover outstanding issuance.
Yield Ban Remains Without Proposed Presumption
The GENIUS Act continues to prohibit permitted issuers from paying interest or yield solely for holding, using or retaining a payment stablecoin. However, the OCC removed the proposed rebuttable presumption that could have automatically treated certain affiliate or third-party arrangements as violations. Instead, the regulator will examine individual arrangements based on their facts and economic substance while retaining authority to address attempts to evade the statutory prohibition. The change sharpens the distinction between direct issuer yield and the broader stablecoin rewards debate.
Capital rules follow a similarly tailored approach. The OCC will set minimum capital requirements according to each issuer’s risk profile rather than imposing one standardized ratio across the industry. A separate operational backstop must generally equal the issuer’s total expenses over the preceding 12 months, although certain one-time costs may be excluded with regulatory approval. The agency explicitly declined to impose an additional capital buffer.
The October rule also leaves financial-crime compliance unfinished. Proposed KYC and recordkeeping requirements for stablecoin issuers remain subject to separate rulemaking rather than becoming final through this package. January 18 therefore marks the start of the GENIUS Act’s operative framework, not the end of federal stablecoin rulemaking. Prospective issuers must prepare licensing, reserve, redemption, capital and reporting systems while additional AML and sanctions requirements continue toward finalization.
Jack Reynolds is SatoshiPick’s infrastructure mind. Based in Denmark, he follows Bitcoin, Ethereum, Layer 1 networks, stablecoins and DeFi with a practical question always in the background: does this actually make crypto work better?
His articles focus on the systems beneath the headlines: settlement rails, protocol upgrades, stablecoin usage, DeFi coordination and the regulatory limits around them. Jack avoids turning technical coverage into a maze. He explains what is live, what is still experimental and why the difference matters.