OCC Targets November for Final Stablecoin Rules Under the GENIUS Act
The statute passed in 2025. The rules that make it operable are still being written, and issuers are planning against a March 2027 effective date.
The GENIUS Act became law in July 2025. Fourteen months later the rules that turn it into something a compliance officer can act on are still in draft, with the Office of the Comptroller of the Currency targeting November for a final text. On the usual timetable that puts the effective date somewhere near March 2027.
The gap between statute and rulebook
This lag is ordinary in financial regulation and disorienting for an industry unused to it. A statute sets the perimeter; the rules decide what falls inside it. Issuers have spent more than a year knowing they will be regulated without knowing precisely how, and the OCC, FDIC and FinCEN have each been working a different piece of the same problem.
The provision doing the most work
Section 4(a)(11) prohibits a permitted payment stablecoin issuer from paying interest or yield to holders solely in connection with holding or using the coin. That single clause has reshaped product design across the sector. The economics of a fully reserved dollar token are straightforward — the issuer earns on the reserves — and the statute forecloses the obvious way of sharing that with users.
What followed was predictable and is worth watching closely: yield did not disappear, it moved. Tokenised money market funds, wrapped deposit products and DeFi vaults now sit adjacent to compliant stablecoins, offering the return the coin itself cannot. Whether regulators read those structures as separate products or as the same economics wearing a different label is the live question.
Who is affected
The Act allows any FDIC-insured bank to issue payment stablecoins through a subsidiary, with the first such products expected in late 2026 or early 2027. That provision is the reason several large institutions have quietly stood up digital asset subsidiaries this year.
For existing issuers the question is narrower and harder: whether a reserve model built before the rules existed can be brought inside them without being rebuilt.