BPI Seeks Clearer OCC Disclosure on Stablecoin Reward Reviews

The Bank Policy Institute (BPI) is urging the Office of the Comptroller of the Currency (OCC) to explain how it will review stablecoin rewards, saying the final rule leaves decisions and disclosure unclear.

On Saturday, Oct. 24, BPI renewed the call in a newsletter, criticizing the lack of a transparent process for reviewing third-party arrangements and disclosing the outcomes. The OCC finalized its GENIUS Act rule Wednesday, Oct. 21.

“The permissibility of yield arrangements should be clearly defined, not determined by opaque interpretation,” said Paige Pidano Paridon, BPI’s executive vice president and co-head of regulatory affairs.

The OCC removed a proposed presumption that certain arrangements between issuers and affiliates or related third parties violated the yield prohibition. The agency will instead assess arrangements based on their facts and circumstances. The rule does not list which arrangements are permitted or prohibited, and the OCC retains authority to address evasion.

The GENIUS Act bars permitted payment stablecoin issuers, foreign payment stablecoin issuers and their affiliates from paying interest or yield solely in connection with holding, using or retaining a payment stablecoin. A payment through an intermediary on an issuer’s behalf can fall under the ban when it is tied solely to holding, using or retaining the stablecoin. Other intermediary arrangements receive a fact-specific review.

The rule does not give programs that began before the law took effect an automatic exemption. Those programs will be assessed under the same standard as later ones.

BPI has also warned that stablecoin reward programs could draw deposits away from banks. The Blockchain Association welcomed removal of the proposed presumption. Chief Policy Officer Lindsay Fraser said, “Its removal brings the final rule more closely in line with the statutory text.”

The OCC rule and the GENIUS Act take effect Jan. 18, 2027.