Less than three months remain until the GENIUS Act takes effect. The OCC has finalized its rules, but the application window for issuers still hasn’t opened.
#OCC Publishes First Final Rule Under the GENIUS Act
On October 21, the OCC issued its final rule and accompanying bulletins (Bulletins 2026-50 and 2026-51). Both the rule and the Act take effect on January 18, 2027. The bulletin puts it plainly: starting that day, issuing payment stablecoins in the United States without approval will carry criminal liability.
What about existing issuers? The bulletin says they can apply for an exemption of up to 12 months if they have a “substantially complete” application pending with the OCC before January 18. The catch is that the OCC won’t start accepting applications until the White House Office of Management and Budget approves the application forms. The OCC says it will announce the opening date separately.
There’s also some leeway on rewards. Banking Dive reported the same day that the rule prohibits issuers from paying interest directly to token holders, while rewards offered through third parties will be assessed on a case-by-case basis.
I’m inclined to see this rule as the exam being handed out in advance. The real pressure will come in the final weeks of the year, as issuers race to get their applications in before January 18.
#OCC Publishes First Final Rule Under the GENIUS Act
On October 21, the OCC issued its final rule and accompanying bulletins (Bulletins 2026-50 and 2026-51). Both the rule and the Act take effect on January 18, 2027. The bulletin puts it plainly: starting that day, issuing payment stablecoins in the United States without approval will carry criminal liability.
What about existing issuers? The bulletin says they can apply for an exemption of up to 12 months if they have a “substantially complete” application pending with the OCC before January 18. The catch is that the OCC won’t start accepting applications until the White House Office of Management and Budget approves the application forms. The OCC says it will announce the opening date separately.
There’s also some leeway on rewards. Banking Dive reported the same day that the rule prohibits issuers from paying interest directly to token holders, while rewards offered through third parties will be assessed on a case-by-case basis.
I’m inclined to see this rule as the exam being handed out in advance. The real pressure will come in the final weeks of the year, as issuers race to get their applications in before January 18.