The GENIUS Act Is Here — What Changes for Stablecoins? w/ Jonathan Gould, U.S. Comptroller of the Currency

The OCC has released its final rule implementing its part of the GENIUS Act after about 15 months of work. Jonathan Gould said the agency expects to begin accepting applications from payment stablecoin issuers on January 18, when the law takes effect. The rule covers the OCC’s role; a separate rule on Bank Secrecy Act and anti-money-laundering requirements is still being developed with Treasury. Gould expects scores of applications, but said the agency will assess each issuer’s business plan and relationships case by case.

The Act establishes a federal framework for payment stablecoins, and Gould said the OCC wants to welcome their issuance and related financial intermediation into the banking system. He expects stablecoins to make payments faster and more efficient, particularly across borders. He also said they could reinforce the dollar’s global role and create demand for U.S. Treasury securities. Those potential benefits sit alongside the need for safeguards and supervision as issuers enter a regulated framework.

Reserve requirements are a central safeguard. The law specifies which assets may back payment stablecoins, while the OCC’s rule adds detail on liquidity and backing. Gould said supervision is intended to ensure issuers hold assets that can be liquidated to meet redemptions, whether requests come individually or in high volume. He linked that responsibility to the OCC’s original role, established in 1863, of ensuring that bank-issued notes were backed by assets commensurate with their stated value.

The OCC plans to supervise federally qualified payment stablecoin issuers consistently while applying regulatory principles to each issuer’s circumstances. Issuers will provide weekly and monthly reports covering activity and reserves, and the agency has developed an issuer rating system similar to, but not identical to, its approach to rating banks. Gould said the framework is not fixed in stone: the OCC will reassess it as applications and market structures emerge, seeking to provide clarity without over-regulating or over-structuring a nascent industry.

The final rule leaves the treatment of rewards less prescriptive than the OCC’s proposed approach. Gould said the proposed rebuttable presumption was intended to test how to implement the Act’s anti-evasion requirement. The final rule instead returns to the statute’s language on yield or rewards and does not draw categorical lines around potentially evasive arrangements involving third parties or affiliates. Gould said the OCC wants to review actual applications before making blanket judgments, leaving those arrangements to be assessed in context.

For cross-border stablecoin payments, Gould said the OCC is working with Treasury on broader geopolitical goals, including reciprocity arrangements with non-U.S. jurisdictions. He also argued that stablecoin transparency and auditability can help supervised institutions meet know-your-customer responsibilities and support law enforcement. The approach therefore pairs the prospect of faster payments and broader dollar use with reserve oversight, reporting, and scrutiny of issuer structures, while leaving room to adjust rules as the market develops.