Summary
The GENIUS Act rulemaking deadline (July 18, 2026) requires six federal agencies to publish final rules simultaneously. The OCC's framework is the most consequential: $5M minimum capital floor, three-tier liquidity (10% same-day, 30% within 5 days, 60% in standard reserves), and no deposit insurance for holders. The no-yield prohibition permanently separates payment stablecoins from yield-bearing instruments. Issuers get 120 days to comply after final rules are published.
Key Points
- Statutory deadline: July 18, 2026 — exactly one year after GENIUS Act passage
- Six agencies: OCC, FDIC, NCUA, Treasury, FinCEN, OFAC — all must publish simultaneously
- OCC capital floor: $5M minimum equity for federal stablecoin issuers
- Three-tier liquidity:
- Tier 1 (10%): Same-day redemption in Fed deposits or cash equivalents
- Tier 2 (30%): Within 5 business days in high-quality liquid assets
- Tier 3 (60%): In standard reserve assets including securities
- FDIC: No deposit insurance for stablecoin holders — regardless of issuer charter
- No-yield prohibition: Payment stablecoins cannot pay interest or yield
- AML/Sanctions: Full BSA-compliant AML programs, 24-hour OFAC screening cycles
- Compliance window: 120 days after final rules (~January 18, 2027)
- State-licensed operators: Must upgrade to federal standard or restrict US operations
- Winners: Big banks (JPMorgan, BofA, US Bancorp) — $5M is rounding error
- Squeezed: Crypto-native startups need $5M equity before federal charter path
- Tether: Not signaled compliance intent; technically offshore