On October 21, the OCC published its final rule implementing the GENIUS Act, setting January 18, 2027, as the deadline for permitted payment stablecoin issuers and certain foreign issuers under its authority. The rule introduces reserve, redemption, capital and risk-management requirements simultaneously, including a permanent minimum capital requirement of 5 million dollars, while existing issuers may seek a temporary exemption. The presumption that third-party rewards were unlawful by default has been removed: reward programs will be reviewed case by case, although the OCC may act against clear circumvention. Ordinary redemptions remain due within two business days, but issuers must request an extension from the OCC whenever redemptions exceed 10% of outstanding tokens within 24 hours. The anti-money-laundering framework, Bank Secrecy Act requirements and OFAC sanctions will be addressed separately with the Treasury.
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