Under US rules, a stablecoin redemption now counts as done when the issuer sends the dollars, not when it burns the token. That is one sentence in the 721-page final rule the Office of the Comptroller of the Currency released on 21 October, and for anyone building on USDC or PYUSD it matters more than the yield row that has dominated the coverage.
The rule creates a new 12 CFR Part 15, "Payment Stablecoins", and it appears in the Federal Register today at 91 FR 67000. It takes effect on 18 January 2027, the date the GENIUS Act itself switches on. It is the first final rule from a primary federal stablecoin regulator. The Federal Reserve's two proposals are open for comment until 30 November, and the FDIC has not finalised anything yet.
What Does the OCC GENIUS Act Final Rule Cover?
Part 15 covers national banks, federal savings associations, federal branches, foreign issuers, nonbanks seeking Federal qualified issuer approval, and state issuers under OCC enforcement. The OCC's impact analysis counts 39 entities, including at least 12 it does not supervise today, and puts baseline 2027 issuance at $272.3bn. For scale, USD stablecoins stand at roughly $303bn this week on DefiLlama, with USDT at $182.5bn and USDC at about $72bn.
Anti-money laundering and sanctions rules are not in it. They sit in separate proposals from the OCC and from FinCEN and OFAC, so the wallet-screening obligations developers care about most are still not final.
GENIUS Act Reserve Requirements: 5% Cash and a 40% Cap
Eligible reserves are cash, Fed balances, demand deposits, Treasuries with 93 days or less to run, overnight repo against them, government money market funds, and tokenised versions of these. The OCC drew about 328 comments on its February proposal, and the changes since are where the policy shows.
| Requirement | Proposal (Feb 2026) | Final rule (Oct 2026) |
|---|---|---|
| On-demand deposits or Fed balances | 10% minimum | 5% minimum |
| Single counterparty | 40% cap | 40% cap, excluding US government, custodians and centrally cleared repo |
| Liquidity safe harbour | 30% weekly liquidity, 20-day maturity cap | Dropped |
| Withdrawing surplus reserves | Monthly | Any time, after due diligence |
| Capital | $5m floor, bank-style CET1/AT1 tiers | $5m floor, GAAP equity less intangibles |
| Operational backstop | 12 months of expenses | 12 months of expenses, up to half in subordinated debt |
| Redemptions above 10% in 24 hours | Automatic 7-day extension | Notify OCC within 24 hours, may request extension |
Read the full article on tomcn.uk →
About the Author
I'm Tom Wang, an AI Developer & Fintech Developer — building AI agents, crypto payment infrastructure, and cross-border payout systems with Rust, Go, and TypeScript. Based in London, UK.
Currently open to new opportunities in fintech, crypto payments, and AI agent engineering.
