The “licensing era” for stablecoins officially begins today
On October 21, the OCC published the first final rule under the GENIUS Act
More than 700 pages; takes effect January 18, 2027
The OCC is the first to complete the process
The changes are about rewards
The final rule keeps the provision that “issuers may not pay interest directly”
But removes the draft’s presumption that “third-party arrangements may be unlawful”
Instead, each case will be reviewed individually
Rebates and channel incentives from exchanges
Move from “prohibited in advance” to “enforced after the fact”
This loosens restrictions for trading platforms
Banks had wanted a blanket ban
The battle over bank deposits and crypto platforms isn’t over yet
Reserve requirements are relaxed
The 20-day weighted-average maturity cap is eliminated
Excess reserves can be withdrawn at any time
But full reserve backing and redemption requirements remain unchanged
The real test is USDT
Tether is registered in El Salvador, making it a foreign issuer
It needs the Treasury to determine that its oversight is “comparable”
As of October 19, it hasn’t
After January 18, 2027, it cannot legally be sold to U.S. customers
Starting July 18, 2028, U.S. platforms cannot use unlicensed stablecoins
USDC, by contrast, stands to benefit
Its reserves are short-term U.S. Treasuries and cash, so they’re already compliant
Circle has applied for an OCC trust bank charter
Moving stablecoins to a licensing regime is a good thing in the long run
But USDT’s path to compliance is the biggest uncertainty
With a market cap of $180 billion, any trouble could spill over into the entire market
In terms of what to do
Don’t bet on USDT running into trouble—that’s a systemic risk
What to watch is the growing share of compliant stablecoins
The moat for stablecoins is shifting from scale to licenses 👀
$USDT
#OCC发布GENIUS法案首个最终规则 #GENIUS法案预计2027年1月18日生效 #稳定币
On October 21, the OCC published the first final rule under the GENIUS Act
More than 700 pages; takes effect January 18, 2027
The OCC is the first to complete the process
The changes are about rewards
The final rule keeps the provision that “issuers may not pay interest directly”
But removes the draft’s presumption that “third-party arrangements may be unlawful”
Instead, each case will be reviewed individually
Rebates and channel incentives from exchanges
Move from “prohibited in advance” to “enforced after the fact”
This loosens restrictions for trading platforms
Banks had wanted a blanket ban
The battle over bank deposits and crypto platforms isn’t over yet
Reserve requirements are relaxed
The 20-day weighted-average maturity cap is eliminated
Excess reserves can be withdrawn at any time
But full reserve backing and redemption requirements remain unchanged
The real test is USDT
Tether is registered in El Salvador, making it a foreign issuer
It needs the Treasury to determine that its oversight is “comparable”
As of October 19, it hasn’t
After January 18, 2027, it cannot legally be sold to U.S. customers
Starting July 18, 2028, U.S. platforms cannot use unlicensed stablecoins
USDC, by contrast, stands to benefit
Its reserves are short-term U.S. Treasuries and cash, so they’re already compliant
Circle has applied for an OCC trust bank charter
Moving stablecoins to a licensing regime is a good thing in the long run
But USDT’s path to compliance is the biggest uncertainty
With a market cap of $180 billion, any trouble could spill over into the entire market
In terms of what to do
Don’t bet on USDT running into trouble—that’s a systemic risk
What to watch is the growing share of compliant stablecoins
The moat for stablecoins is shifting from scale to licenses 👀
$USDT
#OCC发布GENIUS法案首个最终规则 #GENIUS法案预计2027年1月18日生效 #稳定币