January 18, 2027 is the start date. The OCC has finalized the first US rule under the GENIUS Act, setting the stablecoin rulebook for issuers under its oversight.
Key points:
- The OCC is the first US regulator to finalize a GENIUS Act stablecoin rule.
- It sets reserve, redemption, custody, capital and risk standards.
- Third-party reward arrangements will be judged case by case.
The rule applies to subsidiaries of national banks, federally approved nonbank issuers, some state-qualified issuers and foreign issuers, and to certain custody work at OCC-supervised firms. Anti-money-laundering and sanctions requirements will arrive separately with the Treasury Department.
The rewards section deserves attention. The GENIUS Act prohibits issuers from directly paying interest, and an earlier OCC proposal presumed some third-party deals could be unlawful. The final text removes that presumption while preserving the power to act against clear evasion.
In my view, this is the kind of clarity that pushes activity toward regulated issuers rather than offshore workarounds. Watch for the OCC to announce when applications open.
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