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On October 21, 2026, the Office of the Comptroller of the Currency issued a final rule implementing the GENIUS Act for payment stablecoin issuers subject to OCC supervision. The source, a law-firm client alert, states that the final rule eases several key proposed requirements and introduces new issues, but the excerpt does not enumerate the specific provisions changed, so its effect on reserve, redemption, disclosure, or supervisory expectations cannot be described with confidence from this material alone.

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On Oct. 21 the OCC published a 721-page final rule (RIN 1557-AF41) implementing the GENIUS Act for permitted payment stablecoin issuers and foreign payment stablecoin issuers within its jurisdiction, and for certain custody activities of OCC-supervised entities. It takes effect Jan. 18, 2027; BSA/AML and OFAC requirements are deferred to a separate Treasury-coordinated rulemaking. The final rule departs from its proposal: the rebuttable presumption that related-third-party arrangements are prohibited yield payments is eliminated, leaving the statutory yield ban as a fact-specific inquiry; three permitted PPSI activities are added (holding nonpayment stablecoins as principal to pay fees, establishing reserve-asset trusts, managing FX risk, subject to conditions); reserve diversification shifts to a principles-based approach with stress-testing and buffer requirements; no minimum insured-deposit amount is required of custodians; and PPSIs must notify the OCC within 24 hours if redemptions exceed 10% of a brand's outstanding issuance value, with discretion to extend redemption timelines

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OCC has finalized its stablecoin framework under the GENIUS Act, according to a Jones Day alert dated 26 October 2026. The source material available for this briefing is limited to the alert's headline, so the rule's specific provisions — the boundary between permitted payment stablecoins and other categories, issuer eligibility, reserve, disclosure, capital and liquidity treatment, custody and anti-money-laundering expectations, and the treatment of issuer applications — are not confirmed here and should be read directly from the adopting text.

What is confirmed is that the prudential regulator for national banks and federal savings institutions has moved from proposal to final rule on stablecoin issuance and related activity. That is the point in the statutory sequence at which bank and fintech clients can map product roadmaps, chartering and partner arrangements onto a settled federal framework rather than an interim one, and at which counsel can begin scoping supervision, compliance and disclosure obligations.

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What happened: On October 21, 2026, the Office of the Comptroller of the Currency issued a final rule implementing the GENIUS Act for permitted and foreign payment stablecoin issuers under its jurisdiction, and for related custody activities of OCC-supervised entities. The reporting comes from Orrick, Herrington & Sutcliffe's client alert.

Why sophisticated counsel and clients care: the GENIUS Act created a federal regime for payment stablecoins, and the OCC rule is the first rulemaking to translate the statute into binding requirements for issuers the OCC supervises — including entities seeking to serve the US market from abroad. Because the rule reaches both issuance and custody by OCC-supervised institutions, its scope is likely to touch banks, trust companies, and fintech partners that hold or service stablecoin reserves or customer balances. It also draws the perimeter between federal supervision and state regimes for issuers falling outside OCC jurisdiction, the point on which many market participants have been waiting for the first concrete line.

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On October 21, 2026, the Office of the Comptroller of the Currency issued a final rule implementing the GENIUS Act as it applies to payment stablecoin issuers, according to a Sheppard Mullin alert published October 23, 2026. The alert reports the rule's issuance and its subject but does not set out the specific provisions, so the practical contours of any reserve, capital, custody, redemption, examination or supervisory requirements should be confirmed against the Federal Register text rather than assumed.

Why sophisticated counsel should care: GENIUS Act implementation is the gating item for any bank, payment institution or fintech weighing a payment stablecoin product, and the OCC's rule is the first agency-level implementation milestone for its supervised cohort. Clients with issuer, sponsor or reserve-provider roles will need to map rule obligations against product design, partner agreements and marketing claims, and will want to assess how OCC expectations interact with the implementing framework being developed by other federal agencies.

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On October 21, 2026, the Office of the Comptroller of the Currency issued a final rule implementing the GENIUS Act for payment stablecoin issuance, covering national banks, federal savings associations, federal branches and their subsidiaries, foreign payment stablecoin issuers, and nonbank or state entities pursuing federal qualified payment stablecoin issuer status. The rule takes effect January 18, 2027; Bank Secrecy Act, anti-money laundering and OFAC sanctions rules are reserved for a separate Treasury-coordinated rulemaking. The OCC also finalized revised weekly and quarterly reporting forms for permitted and foreign issuers, open for 30-day comment, and issued a bulletin on waiver and application procedures.

Separately, Treasury proposed regulations under the 21st Century ROAD to Housing Act restricting large institutional investors from purchasing single-family homes and codifying Executive Order 14376.

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The Office of the Comptroller of the Currency promulgated a final regulation implementing GENIUS Act requirements for permitted payment stablecoin issuers and foreign payment stablecoin issuers within the OCC's jurisdiction. The rule also covers certain custody activities by OCC-supervised entities and revises capital adequacy standards, prompt corrective action regulations, assessment of fees, and OCC rules of practice and procedure. The same daily update flags two cross-border supervisory items: an SEC memorandum of understanding with France's Autorite des Marches Financiers to facilitate consultation and information-sharing on SEC-regulated investment advisers and investment companies and AMF-supervised investment service providers, and the SEC-FSA Autumn Financial Regulatory Dialogue held in Tokyo on October 19. NCUA separately announced a 13th round of deregulation proposals covering nonconforming investment special reserves, conversion to a state-chartered credit union, and member notification of administrative changes.

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SDNY filed a civil forfeiture complaint on Sept. 14, 2026 seeking approximately $61 million in Tether (USDT) stablecoins, alleging the funds are proceeds of crime connected to Iranian oil sales. The action is notable in two respects: it targets a large block of stablecoin balances rather than bank accounts or physical assets, and the underlying conduct concerns a heavily sanctioned commodity trade. For digital-asset clients, the case bears on how the U.S. government unwinds stablecoin holdings it asserts are criminal proceeds — through court-ordered forfeiture, administrative processes or negotiated transfers — and on the tracing, commingling and segregation questions issuers, exchanges and custodians will face. Sanctions, financial-crime and market-conduct teams should also read it as a template for linking on-chain settlement to sanctioned counterparties and Iranian oil channels. Watch for the response deadline, any third-party claims of superior rights to the seized tokens, and whether the complaint is amended to add entities, wallets or additional assets. Detail is limited to a s

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The Federal Reserve has proposed two rules under the GENIUS Act: one setting application requirements for insured state member banks seeking approval for a permitted payment stablecoin issuer (PPSI) subsidiary, and one governing Federal Reserve-supervised PPSIs, reserve-asset custody providers, tying restrictions, transition of state-supervised issuers, permissible digital-asset activity for supervised banking organizations, and capital treatment of a consolidated PPSI subsidiary. Separately, Treasury, on behalf of the Stablecoin Certification Review Committee, issued an interim final rule on certifying state stablecoin regimes as substantially similar to the federal framework — effective on issuance and allowing a placeholder submission within the one-year state deadline. Comments on both actions are due November 30, 2026.

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What happened: on September 24, 2026 the Federal Reserve Board asked for public comment on two proposed rules implementing the Board's responsibilities under the GENIUS Act. The proposals set out a supervisory framework for payment stablecoin issuers that are, in the Fed's framing, directly supervised by the Board rather than by another federal prudential regulator.

Why sophisticated counsel should care: stablecoin regime design is now moving from statute to operating rules. Reserve requirements, redemption and disclosure standards, custody and segregation, and the supervisory examination and enforcement perimeter all become concrete for institutions weighing whether to issue or distribute a bank-permitted stablecoin. For banks, fintech distributors, merchant acquirers, and corporate treasury teams, the proposals will shape product design, partner selection, and how stablecoin settlement is documented in commercial agreements. The two-rule structure also suggests a division of subject matter between the Board and other agencies, which matters for clients operating across both perime

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What happened: On September 24, 2026, the Board of Governors of the Federal Reserve System issued two companion notices of proposed rulemaking to implement the Board's responsibilities under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). These are proposals, not final rules, so nothing is in force and the requirements remain subject to notice and comment. Reporting on the two notices is thin; specific provisions, comment periods and effective dates are not detailed in the available material and should be confirmed against the Federal Register text.

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On Oct. 1 the SEC proposed a 760-page framework under the Advisers Act and Investment Company Act letting registered advisers and registered funds, including BDCs, self-custody crypto assets if a permitted custodian is unavailable, and maintain assets with state trust companies subject to diligence on the trust company's authority, policies, audited financials and internal controls. The proposal would add custody disclosure to Form ADV and Form N-CEN, with comments due 60 days after Federal Register publication. Peirce, who left the Commission on Oct. 2 and left it with two sitting members, criticized the drafting of "self-custody."

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What happened: On September 30, the U.S. Treasury Department, on behalf of the Stablecoin Certification Review Committee, issued an interim final rule establishing interim procedural regulations and forms governing the Committee's review of state certifications submitted under Section 4(c) of the GENIUS Act. The rule is procedural rather than substantive — it sets out how certification applications move through review and what filings must look like — but it is the first operative framework for the federal-state division of authority over stablecoin issuer approval.

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On Sept. 30 the U.S. Treasury issued an interim final rule setting out the process and forms for state payment stablecoin regulators to certify their regimes to the GENIUS Act's Stablecoin Certification Review Committee, the Treasury-chaired body that must approve state supervision of issuers with $10 billion or less in consolidated outstanding issuance. Separately, on Sept. 24 the Federal Reserve proposed two rules for Board-supervised issuers: one addressing permissible reserve assets, standardized capital requirements, custody of backing assets and the permissibility of stablecoin activities (23 questions), and a 104-page proposal creating application, hearing and appeal procedures for banks seeking approval for a stablecoin-issuing subsidiary (254 questions). Comments on all three close Nov. 30.

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According to an Orrick alert, the Federal Reserve requested public comment on September 24 on two proposed rules implementing the GENIUS Act, enacted in July 2025 to create a regulatory framework for payment stablecoins. The first proposal would establish reserve, capital and related requirements for issuers; the excerpt available here does not describe the second proposal's subject matter, so its scope should be confirmed against the full text.

Why sophisticated counsel should care: GENIUS Act implementation is moving from statute into supervised rulemaking, and the reserve and capital framework determines what backs stablecoin par, how issuer balance sheets compare with bank deposits and money market funds, and what supervisory perimeter issuers and their sponsors now operate inside. The same rulemaking touches banking, payments and corporate treasury teams at once — issuer sponsors, banks pursuing issuance or custody relationships, and clients with stablecoin settlement or cross-border payments mandates.

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