OCC Denies Automatic Compliance for Existing Stablecoin Rewards Programs

The Office of the Comptroller of the Currency (OCC) will not automatically treat stablecoin rewards programs that predate the GENIUS Act as compliant, leaving each arrangement subject to individual review.

The final rule, issued Wednesday, offers no exemption for older programs. Rewards established before the law will face the same standard as those created afterward. It is the first final GENIUS Act rule from a federal banking regulator.

The law bars payment stablecoin issuers from paying holders interest or other yield solely because they hold, use or retain a token. Payments made through intermediaries may also be covered when they are made on an issuer’s behalf. A reward tied partly to another activity may fall outside the restriction, depending on the arrangement.

The OCC removed a proposed presumption that certain arrangements involving affiliates or related third parties breach the yield ban. It will assess the facts of each case and retains authority to act against attempts to evade the law.

The broader rule sets requirements for stablecoin issuers under OCC oversight, including foreign issuers, and for certain custody activities. Payment stablecoins are digital assets designed for payments and redemption at a fixed monetary value.

The OCC will announce separately when it will begin accepting issuer applications and waiver requests. The final rule and the GENIUS Act take effect Jan. 18, 2027.