OCC Finalizes GENIUS Act Stablecoin Rule; Two Filings Due Before Jan. 18
The OCC has finalized its GENIUS Act implementing rule for stablecoin issuers within its supervision, adding a new 12 CFR part 15 and requiring two filings from existing issuers before January 18.
Per an Orrick alert, the Office of the Comptroller of the Currency has finalized the rule implementing the GENIUS Act for stablecoin issuers subject to OCC supervision, adding a new 12 CFR part 15 and amending existing regulations; the firm's summary says issuers already under OCC supervision must make two separate filings before January 18 (the excerpt reviewed here does not specify the filing types or deadline year, so treat those details as reported rather than confirmed).
Why sophisticated counsel care: this is the first completed federal prudential framework for payment stablecoin issuance under the GENIUS Act, moving the regime from statute to operative supervision rules for banks, fintechs and payments companies that issue or plan to issue dollar-denominated stablecoins. The rule text should govern chartering and supervisory expectations, permitted activities, reserve and disclosure obligations, and the transition path for issuers already in the market. A missed filing can affect the ability to keep issuing, and clients may need to align deposit, treasury and money-transmission arrangements with the new perimeter.
Concrete next steps: pull the final 12 CFR part 15 text, map each issuer product against the new requirements, calendar both filings and supporting documentation, and monitor the OCC's companion guidance and FAQs, plus parallel FDIC and Federal Reserve rulemakings and any deadline changes.