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OCC Finalizes Payment Stablecoin Reserve and Custody Rules Under GENIUS Act

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TL;DR

The OCC finalized GENIUS Act rules covering stablecoin reserves, redemptions, risk management and certain custody activities, with the framework taking effect January 18, 2027.

Issuers must maintain reserve assets at least equal to outstanding stablecoins, while redemption requests must be processed within two business days under the rule.

The OCC kept the stablecoin yield ban, dropped a proposed related-party presumption, and left BSA, AML and sanctions requirements for separate rulemaking.

The Office of the Comptroller of the Currency finalized rules implementing the GENIUS Act for payment stablecoin issuers under its jurisdiction, setting standards for reserves, redemptions, risk management and certain custody activities. In its official announcement , the OCC said the framework takes effect January 18, 2027. The final rule moves key stablecoin requirements from proposal to binding regulation on that date. The framework adds detail to the broader debate over stablecoin reserve requirements .

OCC Sets Reserve, Redemption and Custody Standards

Permitted issuers must maintain reserve assets with a value at least equal to outstanding payment stablecoins, preserving the GENIUS Act’s core 1:1 backing requirement. The rule also requires issuers to maintain liquidity and diversification controls capable of supporting timely redemptions. Redemption requests generally must be processed within two business days, establishing an outer limit rather than a target settlement time. The OCC says issuers may redeem sooner, while extensions are limited to circumstances allowed under the regulatory framework.

The final framework also addresses how reserves can be held and supervised. It permits self-custody and affiliate custody in certain circumstances while retaining requirements around eligible financial institutions, segregation and risk controls. Responsibility for complying with reserve requirements remains with the stablecoin issuer even when third-party custodians hold the assets. That distinction places custody inside a governance framework, similar to issues examined in institutional crypto custody , where operational responsibility extends beyond simply controlling private keys.

The OCC also finalized the GENIUS Act prohibition preventing issuers from paying interest or yield solely for holding, using or retaining a payment stablecoin. However, it removed a proposed rebuttable presumption aimed at certain affiliate or third-party payment arrangements. The yield ban remains, but the final rule abandons the proposal’s presumption for related-party structures. The agency said it can still act against arrangements designed to evade the prohibition, keeping enforcement authority while narrowing the rule’s earlier formulation.

The regulation applies to permitted payment stablecoin issuers, foreign issuers and certain OCC-supervised custody activities. Separate rulemaking will address Bank Secrecy Act, anti-money-laundering and sanctions requirements, while the OCC will announce later when it begins processing issuer applications and waiver requests. The October decision finalizes the prudential framework but does not complete every component of the GENIUS Act. The next phase will intersect with developments such as OCC-supervised stablecoin custody and the broader federal stablecoin framework .

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