The GENIUS Act, signed on July 18, 2025, prohibits permitted stablecoin issuers from paying yield to people for merely holding their stablecoins. On February 25, 2026, the Office of the Comptroller of the Currency proposed treating certain rewards offered by affiliates or third parties as indirect yield under a rebuttable presumption. After receiving 47 public comments, including submissions from Visa and JPMorgan, the OCC must decide whether to retain the presumption and how to distinguish direct issuer payments from incentives offered by distribution platforms. Coinbase, whose USDC rewards program is tied to Coinbase One memberships, illustrates the stakes for companies that are not stablecoin issuers. The agency expects to finalize the rule by November 2026, a date that can trigger the GENIUS Act framework’s January 18, 2027 effective date or 120 days after the final regulations are issued.
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