The OCC finished its GENIUS Act stablecoin rule (effective Jan 18, 2027), but nobody can apply yet
who it covers, the five requirements, and the yield-program twist
Key takeaway
US bank regulators have finished writing the stablecoin rulebook, but they have not opened the application window. BYDFi's Market Intelligence desk broke down the final GENIUS Act rule the Office of the Comptroller of the Currency published on October 21 (Bulletin 2026-50), and the gap between those two facts is the story.
The image is the official BYDFi Market Intelligence banner for the piece.
How we got here
Law enacted July 18, 2025. Proposed rule February 25, 2026, printed in the Federal Register on March 2. Final rule October 21, 2026. Effective January 18, 2027.
Who falls under it
- National banks and their subsidiaries
- Federal savings associations and federal branches
- Nonbank federal qualified issuers
- Foreign issuers
- State qualified issuers operating under OCC authority
The five pillars
- Reserves: a principles-based approach to diversification and concentration, but daily liquidity minimums and single-counterparty limits stay strict
- Redemption: reliable, prompt redemption at par, including under stress
- Capital and risk: capital buffers plus a new operational backstop
- Custody and audits: reserve assets segregated, independent audits on a regular schedule
- Licensing: how to get approved and when the OCC can revoke
The yield-program twist
The biggest change from the draft: the OCC "declines to presume" that yield or incentive programs that existed before the GENIUS Act are compliant. Each will be judged on its own facts. The agency also dropped the draft's presumptions about affiliate and third-party arrangements. Anti-money-laundering, Bank Secrecy Act and sanctions requirements are carved out entirely and will come in a separate rule written with the Treasury.
What is still missing
The OCC has not said when it will start taking license applications. Issuers have to build capital, custody and risk systems to a January 18 deadline without a portal to file through.
For anyone holding or trading stablecoins, the next useful signal is an OCC bulletin with an intake date, not a chart.
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