OCC Sets Two-Day Redemption Rule for Stablecoins Under GENIUS Act

The Office of the Comptroller of the Currency (OCC) has announced its final rule implementing the GENIUS Act, the US payment stablecoin law, and it takes effect on January 18, 2027. The rule requires issuers it oversees to back stablecoins with reserve assets "on at least a 1 to 1 basis at all times" and caps redemption at two business days.

For anyone holding a dollar stablecoin from an issuer under OCC rules, that is the practical change: every token must be matched by reserves, and a redemption request has a hard deadline. What the rule does not settle yet is when issuers can actually apply for approval. That date is still unannounced.

Reserves and a Two-Day Redemption Clock

The final rule text is specific on redemption. Section 15.12(c)(1) "provides that timely redemption may not exceed two business days following the date of the requested redemption."

Redemption during a rush was one of the sharpest fights in the comment file. The OCC records that "many commenters argued against imposing a freeze on (or extension of) redemption when there is a spike in redemption requests," because such provisions "could accelerate a run." In other words, a holder who fears a freeze has a reason to redeem early, which is exactly how runs start.

Comptroller Jonathan V. Gould pitched the package as "a clear, practical framework for payment stablecoin innovation, with strong standards for reserve backing, redemption, and risk management." The two-day cap and the 1:1 rule are the parts a holder can actually check against an issuer's behaviour.

Yield Presumption Dropped, Left to OCC Discretion

The proposal included a rebuttable presumption on yield. That meant certain transactions involving an issuer's affiliates and related third parties would be treated as breaking the yield ban unless the issuer showed otherwise.

The final rule drops it. "Many commenters opposed the proposal's approach with respect to the yield prohibition," the OCC wrote, and instead of the presumption, "The OCC will exercise its enforcement discretion appropriately."

That leaves a lot resting on one word. Issuers and their partners lose a bright line and gain case-by-case judgment from the regulator. How the final text treats the yield prohibition itself, beyond dropping the presumption, has not been confirmed for this article.

Who the Rule Covers, and What It Leaves Out

According to OCC Bulletin 2026-50, the rule applies to:

• national banks, federal savings associations and federal branches, plus their subsidiaries
• foreign payment stablecoin issuers
• nonbank firms seeking or holding approval as federal qualified issuers
• state qualified payment stablecoin issuers

Most of it sits in a new section of federal banking rules, 12 CFR 15, covering activities, reserves, redemption, risk management, audits, custody, applications, foreign issuers, revocation and a capital backstop. The GENIUS Act generally bars anyone other than a permitted issuer from issuing a payment stablecoin in the US.

Anti-money laundering and sanctions rules are not in this package. The OCC is handling those in a separate rulemaking with the Treasury, and its proposal for that was published in the Federal Register on June 24, 2026.

The OCC received about 328 comments. The formal period closed on May 1, 2026, though late comments were accepted until July 1. Some commenters asked the agency to slow down. It declined, saying "it is important that the OCC's implementing regulations be effective" when the Act itself takes effect on January 18, 2027.

Application Date Still Waits on OMB

Issuers in the US must comply with the GENIUS Act from January 18, 2027, and Bulletin 2026-51 notes that noncompliance carries criminal penalties. Yet the OCC will only start accepting applications once the Office of Management and Budget gives final approval to the application forms. The agency says it will announce that start date in a separate release.

That gap matters less for issuers already in the market. The OCC says it "generally expects to grant requests for waivers from the Prior Approval Requirement for existing issuers currently operating in the United States," unless its review turns up "more compelling reasons to deny the request."

The US date lands ten days after Europe's own cutoff: ESMA has set 8 January 2027 as the deadline for non-compliant stablecoins. The next thing to watch on the US side is the OMB sign-off, because until it arrives, new issuers have a compliance date but no way to file.