The rule was published on October 21 and takes effect on January 18, 2027. It describes how to issue payment stablecoins (coins with an exchange rate pegged to the dollar - USDT, USDC and others): requirements for reserves, redemption, risk management, audit and reporting, custody, as well as oversight of foreign issuers. It covers subsidiaries of national banks, approved nonbank issuers, some state-licensed issuers, and foreign companies operating in the US.
On reserves, the OCC softened the original version: instead of hard limits - a principles-based approach to diversification, but the mandatory 1:1 backing is retained, plus a minimum of daily liquidity and a ban on excessive concentration with a single counterparty.
The main change versus the February draft - the regulator removed preset assumptions about reward programs through exchanges and third-party platforms. The GENIUS Act prohibits an issuer from paying for mere ownership of the coin, and the OCC will review each case individually, relying on the word "solely": a payment that has another reason as well does not fall under the ban. There is no safe harbor for existing programs - and that means 4% on PYUSD at PayPal, 3.75% on USDC in Coinbase One, and up to 4.5% on USDG in Kraken+.
Comptroller Jonathan Gould called the rule "a clear practical framework." Treasury Secretary Scott Bessent compared the GENIUS Act to the National Currency Act of 1863. The OCC has not yet said when it will start accepting applications - it will announce separately. AML and sanctions rules will come out as a separate act together with the Treasury, and the FDIC, FinCEN, OFAC and the Fed have not yet finalized their rules.
Are you holding positions in stablecoins?
First the rules change, then the available instruments and venues. And here's what turns out: in one prop program, stablecoin pairs are the main instrument, in another the list of tradable assets is cut down, and trading at night or over the weekend cuts the drawdown limit. This isn't solved by the price of the challenge, but by whether the risk rules match your actual trading. It's worth checking this before the new regulatory date shakes everything up again.

