INTEL: US finalizes first GENIUS Act rules for stablecoins and crypto rewards

The US Office of the Comptroller of the Currency (OCC) has issued its final rule implementing key provisions of the GENIUS Act, establishing a federal regulatory framework for payment stablecoins and addressing how cryptocurrency rewards programs will be treated.

Announced on October 21, 2026, the rule is scheduled to take effect on January 18, 2027. It represents the first completed implementing rule from a major federal banking regulator under the legislation signed by President Donald Trump in July 2025.

The regulations cover stablecoin issuers under the OCC’s jurisdiction, including certain banks, nonbank issuers and foreign companies seeking to operate in the United States.

OCC establishes stablecoin issuance requirements

The final rule establishes regulatory requirements and approval procedures for companies seeking to issue payment stablecoins under federal supervision.

It addresses reserve management, liquidity, operational safeguards, supervision and custody arrangements.

The OCC also revised its earlier proposed reserve requirements, adopting a more flexible approach to diversification and concentration risks. Issuers must maintain sufficient daily liquidity and avoid excessive exposure to individual counterparties.

These provisions are intended to support stablecoins designed to maintain a stable value against the US dollar.

Existing crypto rewards programs receive no automatic exemption

One of the most consequential elements of the final rule concerns cryptocurrency rewards and interest payments.

The GENIUS Act prohibits stablecoin issuers from paying interest or rewards solely for holding, using or retaining their payment stablecoins.

However, the treatment of rewards offered through cryptocurrency exchanges and other third parties has remained controversial.

The OCC declined to automatically exempt existing rewards programs, meaning companies cannot assume that programs established before the legislation are compliant.

Instead, the regulator will assess individual arrangements based on their structure and circumstances.

The OCC also removed proposed presumptions that would have treated certain arrangements as violations.

This approach leaves room for rewards programs structured around activities beyond simply holding or using stablecoins, although their regulatory treatment will depend on the specific arrangement.

What happens to Coinbase and other crypto exchanges?

Cryptocurrency platforms that provide incentives for holding or using stablecoins may need to review their programs under the new regulations.

The issue is particularly relevant to companies such as Coinbase, PayPal and Kraken, which have offered rewards on selected stablecoin balances or through subscription programs.

Existing programs do not automatically qualify for regulatory exemptions, and the OCC has not established a universal approval for exchange-operated rewards.

The regulator’s approach leaves significant questions about which third-party arrangements will remain permissible.

GENIUS Act implementation begins January 2027

The GENIUS Act was signed into law on July 18, 2025, establishing the first comprehensive federal framework specifically governing US payment stablecoin issuance.

The OCC’s final rule is scheduled to become effective on January 18, 2027.

Other regulators, including the Federal Reserve, Federal Deposit Insurance Corporation and Treasury Department, continue developing separate rules covering their responsibilities under the legislation.

The OCC’s action marks a significant step toward implementing the federal stablecoin framework, but it does not complete every regulatory requirement established by the GENIUS Act.

Additional regulations concerning financial crime prevention, sanctions compliance and other supervisory responsibilities remain under development.

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