Summary
Six federal agencies have published proposed rules to implement the GENIUS Act, with a statutory deadline of July 18, 2026 for final rules. The OCC has emerged as the gravitational center of the federal stablecoin framework, with other agencies aligning their proposals against it. Five proposed rules were published in ten weeks — a striking regulatory pace.
The Six Agencies and Their Proposals
1. OCC (Office of the Comptroller of the Currency)
Proposal published: March 2, 2026 (91 FR 10202)
Scope: Most expansive proposal. OCC is primary regulator for:
- Subsidiaries of national banks and federal savings associations
- Federal qualified payment stablecoin issuers (FQPSIs) — nonbanks, uninsured national banks, federal branches
- State-qualified PPSIs crossing $10B threshold
Key features:
- Counterparty concentration limits on reserves beyond statutory requirements
- Lifecycle-based capital framework (CET1 + additional tier 1 + operational backstop)
- Prior-notice requirement for any change of control of a PPSI
- Presumptive prohibition on interest/yield with limited rebuttal opportunity
- Mandatory consequences for breach: prohibition on new issuance, mandatory liquidation, redemption period extension
- Two-business-day redemption clock with automatic seven-day extension if demands exceed 10% in 24 hours
2. FinCEN (Financial Crimes Enforcement Network) + OFAC (Office of Foreign Assets Control)
Joint proposal published: April 10, 2026 (91 FR 18582)
Scope: AML/CFT and sanctions compliance program requirements for all PPSIs
Key features:
- PPSIs treated as financial institutions under the Bank Secrecy Act
- Four-pillar AML/CFT program: designated compliance officer, internal policies/procedures/controls, ongoing employee training, independent testing
- Customer identification program (CIP) requirements
- Customer due diligence (CDD) and beneficial ownership information (BOI) collection
- Suspicious Activity Report (SAR) filing requirements ($5,000 threshold)
- Currency Transaction Report (CTR) requirements
- Recordkeeping and Travel Rule requirements
- First-ever explicit mandate for an effective sanctions compliance program (five elements: management commitment, risk assessment, internal controls, testing/auditing, training)
- Technical capabilities to block, freeze, and reject impermissible transactions
- Lawful order compliance capabilities
- Information sharing (314(a) and 314(b))
- Special standards of diligence and special measures
3. FDIC (Federal Deposit Insurance Corporation)
Proposal published: April 10, 2026 (91 FR 18534)
Scope: FDIC-supervised PPSIs (subsidiaries of FDIC-supervised IDIs) and custodians
Key features:
- Expressly aligned with OCC proposal "to the extent relevant"
- Permissible activities, reserve composition, two-business-day redemption
- Tier-1-only capital framework (CET1 + additional tier 1, no tier 2)
- Less prescriptive reserve diversification (40% counterparty concentration limit)
- Reliance on supervisory discretion rather than OCC's automatic-consequence regime
- No stand-alone PPSI control filing requirement
- Clarification: deposits held as reserves are insured to the PPSI as corporate deposits, NOT to stablecoin holders on pass-through basis
- Clarification: tokenized deposits are deposits under the FDI Act (technology-neutral)
4. NCUA (National Credit Union Administration)
Proposal published: February 12, 2026 (91 FR 6531)
Scope: Licensing process for FICU subsidiaries seeking PPSI status
Key features:
- Joint application requirement (PPSI + FICU parent)
- PPSIs may be jointly held by multiple FICUs through a CUSO
- Substantive prudential standards in a forthcoming proposal
5. Treasury Department
Proposal published: April 3, 2026 (91 FR 16844)
Scope: Principles for determining state-level regulatory regime "substantial similarity"
Key features:
- Two-tier framework: "uniform requirements" (must match federal) vs "state-calibrated requirements" (some flexibility)
- OCC framework designated as the "baseline for comparison"
- Uniform requirements: reserve asset categories, rehypothecation prohibition, interest/yield prohibition
- State-calibrated: reserve composition above statutory floor, redemption mechanics, capital, operational backstop
- State capital regimes must be anchored in CET1 + additional tier 1
- $10B threshold: issuers approaching it must plan for federal transition
6. Federal Reserve (Board of Governors)
Status: Has NOT yet issued its GENIUS Act NPRM for state member bank PPSIs
Expected: Before July 18 deadline; expected to broadly track OCC and FDIC frameworks
Key Inter-Agency Dynamics
- OCC as gravitational center: Treasury designated OCC framework as baseline for state comparison; FDIC explicitly aligned with OCC
- Convergence more than divergence: Remaining differences include OCC's automatic consequences for breach, prior-notice for change of control, broader interest/yield prohibition
- Comment deadlines: Most closed by June 9, 2026
- Statutory clock: Final rules due July 18, 2026; Act effective earlier of 120 days after final rules or January 18, 2027