OCC Targets November for Stablecoin Rule as GENIUS Act Deadline Slips

The proposed rule covers reserve backing requirements, risk management standards, and capital and liquidity obligations that mirror what traditional depository institutions face. Both bank-affiliated issuers and non-bank entities seeking federal licenses would fall under its scope.

The OCC is not working alone. The FDIC and the National Credit Union Administration have issued parallel proposals designed to align with the OCC's framework. The Treasury Department and FinCEN have weighed in on anti-money laundering and sanctions compliance obligations for stablecoin issuers.

The legislation requires issuers to comply with AML rules and sanctions regimes in ways comparable to banks. It also builds in consumer protection standards that go beyond what most state-level stablecoin regimes have required to date.

The effective date of the GENIUS Act adds another layer of pressure. The law takes effect on either January 18, 2027, or 120 days after final rules are issued, whichever comes first. If the OCC finalizes its rule in November, that 120-day clock would push the effective date to around March 2027. If finalization slips past mid-September 2026, the January 18 statutory date becomes the controlling deadline regardless, compressing the compliance window considerably.