The Bank Policy Institute renewed its criticism in its October 24 newsletter of how the OCC will assess arrangements that pay stablecoin holders through third parties. The banking trade group objects to the removal of a proposed presumption and says the replacement approach does not clearly explain how decisions will be made or disclosed. The dispute concerns the implementation of the issuer yield prohibition within the broader framework established under the GENIUS Act, which takes effect on January 18, 2027. According to the BPI, decisions based on who pays, how the payment is ultimately funded and what behavior earns it would clarify the treatment of rewards, rebates and yield. The BPI presents its concerns about deposits moving into stablecoins as a forecast of competitive and financial effects, rather than evidence of a measurable deposit outflow caused by the final rule.
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