The Proposal would establish many requirements for OCC supervised entities, including reserves, capital standards, redemption timelines, and the extent of OCC supervisory authority.
By Jenny Cieplak, Arthur S. Long, Parag Patel, Yvette D. Valdez, Barrie VanBrackle, Pia Naib, and Deric Behar
On February 25, 2026, the Office of the Comptroller of the Currency (OCC) issued a Notice of Proposed Rulemaking (the Proposal) to implement the Guiding and Establishing National Innovation for US Stablecoins Act (GENIUS Act) for institutions subject to its jurisdiction.
The GENIUS Act was enacted on July 18, 2025, and establishes a comprehensive regulatory framework for payment stablecoin activities in the US. It prohibits any person other than a permitted payment stablecoin issuer from issuing a payment stablecoin in the US. Digital asset service providers may not offer or sell a payment stablecoin to a person in the US unless the payment stablecoin is issued by a permitted payment stablecoin issuer (with an exception for payment stablecoins issued by certain compliant foreign payment stablecoin issuers).
This Client Alert identifies key provisions within the OCC’s Proposal and considerations for market participants.