OCC stablecoin rules explained: what you need to know

The OCC stablecoin rules take effect on 18 January 2027. The Office of the Comptroller of the Currency issued them on 21 October as a new Part 15 of its regulations. With them the OCC puts the GENIUS Act into practice as a licensing regime for payment stablecoin issuers and custodians.

Who the rules cover

The OCC supervises four groups of issuers:

• subsidiaries of national banks, federal savings associations and federal branches;
• nonbank companies approved as federal qualified issuers;
• state-licensed issuers that pass $10 billion in coins outstanding;
• foreign issuers that sell into the United States.

A state issuer that crosses $10 billion must tell the OCC within five days. It then has 360 days to move under federal supervision or stop issuing new coins, law firm Mayer Brown wrote in its review of the final text.

What a national bank may do

The rule lists permitted activities, and the list is closed: issuing and redeeming coins, managing reserves, custody and work that directly supports these. The final text adds three items the proposal lacked. An issuer may hold other crypto assets to pay network fees or for testing, set up reserve trusts and hedge currency risk. Banks may also hold stablecoins in custody for customers under written agreements, including in omnibus accounts.

Each issuer must meet five duties:

• reserves at least equal to the coins outstanding, with 5% or more held as on-demand deposits or Federal Reserve balances;
• redemption within two business days;
• no interest or yield paid to holders;
• disclosure that the coins are not deposits and carry no FDIC insurance;
• a capital floor of $5 million and liquid assets covering 12 months of expenses.

How the rules differ from earlier guidance

Until now banks worked from case-by-case interpretive letters. In 2020 and 2021 the OCC said banks could hold stablecoin reserves and use stablecoins for payments. A late-2021 letter added a condition that banks get supervisory non-objection first, and the OCC withdrew that condition in March 2025. The OCC now swaps those letters for licences and fixed numbers.

The OCC also softened its February proposal. It cut the on-demand deposit minimum from 10% to 5% and dropped a 30% weekly liquidity floor. It removed the automatic seven-day extension for redemptions. Instead, an issuer must notify the regulator within 24 hours if requests pass 10% of its coins in a day. The OCC kept the yield ban but dropped the presumption that affiliate reward programmes break it, as we reported when the rule came out.

What is still missing

The OCC will write anti-money laundering and sanctions rules separately with the Treasury. The OCC has not opened applications yet and will announce the start in a separate news release. An issuer with a near-complete application pending on 18 January may ask for a waiver of up to 12 months.

What it means for you

If you hold a dollar stablecoin issued in the US, from January you get a legal right to redeem within two business days and reserves you can check against the rules. Your issuer will not pay you interest, so any yield offer will come from an exchange or another third party. For the law behind the rule, see our guide to the GENIUS Act.

Based on the OCC news release of 21 October 2026 and Mayer Brown’s review of the final rule. Not legal advice.