The Office of the Comptroller of the Currency is moving faster on stablecoin rulemaking, with Comptroller Jonathan Gould saying on Aug. 19 that the agency wants to finish the main final rules under the GENIUS Act by November.
Speaking at the Wyoming Blockchain Symposium in Jackson Hole, Wyoming, Gould said the OCC had already started work ahead of schedule and is now sorting through industry feedback on the proposal as it works toward a final version.
GENIUS Act implementation is taking shape
The GENIUS Act was signed into law by U.S. President Donald Trump in July 2025. It created the first federal framework in the United States for payment stablecoins, setting rules on reserve assets, redemptions, supervision, custody, and issuer qualifications.
Under the current schedule, the law takes effect on Jan. 18, 2027, or 120 days after the main regulators publish final implementation rules, whichever comes first. If the OCC meets its November target, stablecoin issuers would get a clearer runway to prepare.
Reserves, redemptions and custody are central to the rules
The rules now being drafted by the OCC cover several core requirements for stablecoin issuers, including reserve asset management, token redemption, supervisory arrangements, asset custody, and the application process for companies seeking to become qualified payment stablecoin issuers.
The GENIUS Act requires regulated payment stablecoins to maintain full reserves, backed mainly by U.S. dollars and other highly liquid assets. Larger issuers would also face additional audit and disclosure requirements.
Some technical details are still disputed. Earlier this year, BlackRock submitted comments to the OCC opposing overly strict allocation limits on tokenized reserve assets and asking for a broader set of eligible reserve assets. Those restrictions could directly affect how tokenized money market funds such as BUIDL can be used as stablecoin reserves.
Gould said the OCC will keep considering input from crypto firms and other market participants before formally releasing the rules, which means the final version due in November could differ in some respects from the current proposal.
Digital asset bank charter interest has risen sharply
As the regulatory picture becomes clearer, demand for digital asset banking licenses is also growing in the U.S. financial sector. Gould said the OCC had received 40 new bank charter applications over roughly the past 18 months, and 23 of them included digital asset business plans.
He said digital-asset-related charter activity is about eight times higher than during the four years of the Biden administration. Based on current discussions with prospective applicants, payment stablecoins are now showing up more often in bank business plans.
In recent years, a number of crypto and fintech firms have sought federal bank supervision through the OCC as they look to build businesses spanning stablecoin issuance, digital asset custody, and payments. Payoneer, for example, applied this year to establish PAYO Digital Bank, with plans to issue the dollar stablecoin PAYO-USD and offer digital asset custody services.
Gould said regulators are responsible for preserving the soundness and long-term competitiveness of the banking system while also giving qualified new entrants a chance to enter the market. OCC review of bank applications will remain focused on capital, risk management, governance, and compliance capabilities.
Federal-state split puts focus on the $10 billion line
The GENIUS Act also sets up a dual federal and state regulatory structure. Stablecoin issuers with less than $10 billion in issuance can choose state supervision if they meet the relevant conditions, though those state-level frameworks must be “substantially similar” to federal standards.
The New York State Department of Financial Services has already proposed a stablecoin framework this year that aligns with the GENIUS Act. It keeps 1:1 dollar reserves, redemption rights, and independent audit requirements, while adding reserve concentration limits and risk management standards.
The future U.S. stablecoin market is set to operate under both the federal regime and qualifying state regimes. For larger players such as Circle and Paxos, as well as banks and fintech firms looking to enter the sector, the final rules will directly shape issuer eligibility, reserve allocation, and operating costs.
Policy focus is shifting from legislation to execution
With the GENIUS Act already enacted, the policy conversation in the U.S. is shifting toward implementation. One of the OCC’s main jobs now is to turn the law’s principles into rules that financial institutions and stablecoin issuers can actually follow.
Only a few months remain before the November target. Eligible reserve assets, redemption mechanics, custody requirements, issuer application procedures, and the division of authority between federal and state regulators are all set to be key parts of the final rules.
At the same time, digital-asset-related bank charter applications are increasing, and payment stablecoins are becoming a more common part of financial institutions’ business planning. If the OCC stays on schedule and completes the main rules in November, U.S. stablecoin oversight will move another step from legislation into execution, giving the market a clearer view of compliance requirements before the new regime takes effect in 2027.