Existing U.S. payment stablecoin issuers awaiting OCC approval will need a granted waiver to continue issuing after the GENIUS Act takes effect on January 18, 2027. Under guidance published on October 21, the OCC generally expects to approve substantially complete applications submitted before that date, although it can still deny a request if it identifies more compelling reasons. A waiver may last no more than 12 months from January 18, 2027 and will not automatically excuse compliance with other regulatory requirements. As of October 21, the OCC had not opened applications while awaiting final Office of Management and Budget approval of the forms. A timely application alone will therefore not authorize continued issuance unless a waiver is granted.
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