U.S. OCC issues stablecoin rules effective January 18, 2027

Key Facts

The U.S. Office of the Comptroller of the Currency announced a final rule implementing the GENIUS Act on payment stablecoins, setting January 18, 2027, as its effective date. The rule covers issuance of these stablecoins and related activities, as well as certain custody services at entities under the agency's jurisdiction, according to its regulatory bulletin. Its scope extends to nonbank entities and foreign stablecoin issuers subject to its supervisory authority. Comptroller of the Currency Jonathan Gould said the framework includes "strong standards for reserve backing, redemption and risk management." These standards place the reserves backing stablecoins, their redemption and associated risk management within the regulatory framework announced by the agency.

In a change from its earlier proposal, the agency removed a rebuttable presumption that would have treated certain third-party rewards arrangements as violating the yield ban. It said the presumption could capture permissible arrangements while leaving prohibited ones outside its scope, according to the final rule. The agency described the presumption's scope as "both overinclusive and underinclusive." Rewards arrangements will continue to be assessed under the statutory text and "all relevant facts and circumstances" of each arrangement, according to the document. Rewards therefore remain subject to case-by-case supervisory scrutiny, and dropping the presumption does not constitute blanket approval of arrangements involving such payments.

The agency applies the yield ban equally to issuer payments to stablecoin holders, whether institutions or individuals, according to the final rule. It expects to propose additional regulation clarifying the ban as it gains experience identifying prohibited transactions. The final rule follows a proposal the agency published on February 25, 2026, as part of the process of implementing the payment stablecoin legislation. The agency said it received hundreds of comments on the proposal from cryptocurrency companies, bankers, trade associations, academics and others. President Donald Trump signed the law on July 18, 2025, before the agency moved to draft implementing rules.

In accompanying licensing and waiver guidance, the agency said violations of compliance requirements could carry criminal penalties. The guidance allows eligible applicants to receive a transitional waiver of no more than 12 months, provided they have a pending, substantially complete license application. The waiver is thus tied to the status of the submitted license application and the extent to which it meets requirements, alongside the applicant's eligibility. The agency must decide on a license application within no more than 120 days after deeming it substantially complete, according to the guidance. Acceptance of license and waiver applications awaits final Office of Management and Budget approval of information collection through the application forms.

On supervisory reporting, the agency published revised forms for weekly and quarterly reports covering permitted stablecoin issuers and foreign issuers registered with it. The weekly reporting instructions require disclosure of daily interest income paid to third parties. Parties named in the instructions include affiliates and service providers, according to the reporting document. The agency requested comments on the reporting forms within 30 days of publication of the information collection action in the Federal Register. In parallel, Bank Secrecy Act, anti-money laundering and Office of Foreign Assets Control sanctions requirements will be addressed through a separate rulemaking process in coordination with the Treasury Department.

The announced information collection schedule begins with the weekly reporting date of January 25, 2027, subject to Office of Management and Budget approval. That date follows the final rule's entry into force, according to the implementation and reporting dates set by the agency. The first quarterly reporting date designated for the start of information collection is March 31, 2027. Information collection through that report is also subject to Office of Management and Budget approval, according to the reporting forms bulletin. The announced implementation schedule thus moves from the rule taking effect in January to weekly reporting in the same month, followed by quarterly reporting in March.