EL7.AI
CryptoMedium•12 November 2026•
4 min read

U.S. Stablecoin Rules Require Full Reserves and 5% in Demand Deposits

Key Facts

1The rule and the GENIUS Act take effect on January 18, 2027.
2Reserve assets must cover the value of outstanding stablecoins, with at least 5% held in demand deposits or funds in an account at the Federal Reserve.
3An issuer’s exposure to any single counterparty may not exceed 40% of reserve assets, subject to the rule’s conditions and exceptions.
4Redemptions must be made available within no more than two business days of a request.
5The Office of the Comptroller of the Currency must be notified within 24 hours if redemption requests exceed 10% of outstanding issuance value during 24 hours.

The U.S. Office of the Comptroller of the Currency announced the final rule implementing the GENIUS Act on October 21, 2026, setting reserve and redemption requirements for entities within its supervisory remit. The rule covers permitted payment stablecoin issuers and foreign issuers subject to the office’s jurisdiction, as well as certain custody activities at entities it supervises. It requires reserve assets to equal or exceed the value of outstanding stablecoins at all times. It also requires at least 5% of reserve assets to be held in demand deposits, accounts payable on demand or funds in an account at the Federal Reserve. The framework, along with the GENIUS Act, takes effect on January 18, 2027.

The rule caps an issuer’s exposure to any single counterparty at 40% of reserve assets, with exceptions that include the U.S. government. Other provisions set out exceptions for certain qualified custodians and centrally cleared repurchase agreements. The limit is intended to reduce the concentration of reserve assets with a single counterparty backing outstanding stablecoins. In addition to reserve requirements, the rule requires issuers to make redemptions available within no more than two business days of a request. The rules thus link issuance coverage by reserve assets with a defined deadline for meeting holders’ redemption requests.

The rule requires issuers to notify the Office of the Comptroller of the Currency if redemption requests for a stablecoin exceed 10% of its outstanding issuance value during a single 24-hour period. The issuer must send the notice to the office within 24 hours of exceeding the threshold. The office eliminated the automatic extension of the redemption deadline when requests rise, leaving any extension to its discretion. The office said an automatic extension could amplify volatility or trigger redemption runs, or make them worse if they had begun. This arrangement places the response to large requests under the office’s oversight while retaining the redemption deadline set out in the rule.

The rules require clear disclosure that payment stablecoins are not legal tender and are not issued, guaranteed or endorsed by the United States. They also require disclosure that the stablecoins are not bank deposits and are not covered by federal deposit insurance. The final rule does not include Bank Secrecy Act, anti-money laundering or sanctions requirements overseen by the Office of Foreign Assets Control. The Office of the Comptroller of the Currency said those matters would be addressed in a separate rulemaking in coordination with the Treasury Department. This separates requirements for stablecoin issuance and reserves from the regulatory process for anti-money laundering and sanctions.

The final rule followed a consultation process that began with a proposal issued by the Office of the Comptroller of the Currency on February 25, 2026. The office then set a 60-day period for public comments from the date the proposal was published in the Federal Register. The office said it received hundreds of comments from crypto-focused companies, community bankers, trade groups, academics and others. The GENIUS Act was enacted on July 18, 2025, establishing a regulatory framework for payment stablecoin activities. The final rule is an implementation step for the law for entities within the office’s jurisdiction.

As for license and exemption applications, the Office of the Comptroller of the Currency said it would announce in a separate statement when it would begin accepting and processing them. The office’s GENIUS Act webpage said it was not yet accepting exemption applications or applications from stablecoin issuers. The law and rule are scheduled to take effect on January 18, 2027. Rules covering the Bank Secrecy Act, anti-money laundering and sanctions will also be issued through a separate process in coordination with the Treasury Department. The two-business-day redemption deadline and reserve requirements remain among the provisions set to apply when the rule takes effect.