The Office of the Comptroller of the Currency has finalized rules for federally supervised payment stablecoin issuers, setting reserve, redemption, custody, capital, and risk-management standards that will take effect on Jan. 18, 2027. The most closely watched change gives issuers and their distribution partners more flexibility around rewards programs, replacing a proposed presumption of noncompliance with case-by-case regulatory review.
Released on Oct. 21, the rule implements portions of the GENIUS Act, the stablecoin law signed in July 2025. It establishes the OCC’s operating framework for entities seeking to issue payment stablecoins under federal oversight and puts redemption capacity at the center of the regime.
A payment stablecoin issuer covered by the rule must maintain eligible reserves with a value at least equal to the outstanding supply of its tokens. The OCC permits cash, qualifying bank deposits, short-term U.S. Treasuries, and related instruments as reserve assets. That standard is designed to link every token in circulation to assets that can support customer redemptions, though it does not require reserves to consist solely of physical cash held in bank vaults.
A federal route for bank and nonbank issuers
The final rule outlines several routes to the market. A bank may issue through an approved qualifying subsidiary, while a nonbank firm can apply to become a federally qualified payment stablecoin issuer. The framework also addresses access for certain state-qualified and foreign issuers, subject to the approvals or registrations required under the law.
The OCC has not yet said when it will begin accepting issuer applications or requests for exemptions. That timing will determine how quickly companies can move from planning to formal licensing efforts before the January 2027 effective date.
Issuers will need to build compliance systems that cover the full life of a stablecoin, from minting and reserve management to custody and customer redemption. The rule requires formal policies for redemptions, disclosures of terms and fees, liquidity management, capital planning, audits, and risk controls.
Those requirements place particular pressure on issuers whose operations rely on several outside firms. A stablecoin may be distributed through wallets, payment providers, custodians, and other partners, but the issuer remains responsible for ensuring that its structure can meet the federal standards. The framework therefore reaches beyond the reserve portfolio into the operational links that allow a token to be transferred, converted, and redeemed.
Rewards programs avoid an automatic compliance finding
The OCC’s revised treatment of third-party rewards is likely to draw the most attention from stablecoin platforms and banks. The GENIUS Act bars issuers from paying interest or yield simply for holding, using, or retaining a payment stablecoin. The proposed rule had included a presumption that certain arrangements involving affiliates or third parties could violate that restriction.
The final version removes that presumption. Instead, the OCC will assess arrangements individually, including existing programs.
That leaves room for platforms or commercial partners to offer rewards connected to stablecoin use without every program being automatically treated as prohibited. It also preserves enforcement risk where regulators conclude an issuer is effectively using another company to deliver yield that it could not legally pay itself.
The case-by-case approach gives firms flexibility, but it offers less certainty than a bright-line rule. Platforms that offer rewards will need to examine who funds the program, whether the issuer directs or reimburses it, how eligibility is defined, and whether the arrangement resembles payment for merely holding a stablecoin. Program design, contractual relationships, and marketing language could all shape the OCC’s view.
Banking groups had objected to dropping the proposed safeguard, arguing that stablecoin reward structures could pull funds away from bank deposits that support lending. The Independent Community Bankers of America cited a model projecting that expanded stablecoin adoption could reduce community-bank lending by at least $850 billion. The OCC nevertheless opted against an automatic presumption, favoring supervisory review of individual structures.
Redemptions remain a central test
The final rule also removes a proposed automatic extension for large redemption requests. Under the proposal, issuers could have received up to seven calendar days in certain circumstances when requests received within 24 hours exceeded 10% of outstanding stablecoins.
The OCC dropped that mechanism after warning that an automatic delay could worsen withdrawal concerns. In a fast-moving market, a formal rule that extends redemption timing once a threshold is crossed could give customers an incentive to redeem earlier, rather than reassure them that the issuer has time to manage liquidity.
Issuers must still maintain redemption policies and reserve liquidity sufficient to meet obligations. The final approach places greater weight on an issuer’s own capacity to handle stress rather than providing a preset timetable extension during a heavy outflow event.
That choice makes liquidity planning especially consequential. Firms will need reserves that meet the asset-eligibility rules while also being available quickly enough to honor customer redemptions under the terms they disclose. A reserve portfolio heavily concentrated in assets that cannot be readily converted to cash could create operational problems even if its overall value matches the token supply.
Compliance boundaries take shape
The OCC rule does not settle every issue facing the sector. Anti-money-laundering and sanctions-related requirements will be developed separately, according to the agency. Those rules could add another layer of obligations for issuers, custodians, and payment providers handling stablecoin transfers.
For now, the final text gives the industry a more concrete federal compliance map: qualifying issuance pathways, one-to-one eligible reserves, defined redemption processes, and supervision over the relationships that connect issuers to wallets and rewards programs. Its treatment of third-party incentives ensures that the debate over stablecoin yield will move from broad policy arguments into specific supervisory cases.
For deeper context on these OCC changes and stablecoin policy, read why the GENIUS Act could be the turning point for stablecoins now.
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