GENIUS Act Final Rule: When a Stablecoin Buyer Becomes the Issuer’s Customer, and What the Yield Ban Covers

A dollar stablecoin bought through an exchange or a payments app comes with two relationships: one with the app that sold it, and one with the company that issued it and holds the money behind it. The final rule implementing the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, published by the Office of the Comptroller of the Currency (OCC) on 21 October 2026, decides when the second relationship begins. The GENIUS Act final rule also defines the holder that the law’s ban on stablecoin yield refers to, and drops a presumption against yield arrangements that the American Bankers Association (ABA) wanted kept.

The rule takes effect on 18 January 2027, the same day as the GENIUS Act itself. Its definitions set out who a supervised issuer answers to directly and how far the yield ban reaches into the rewards that holders collect.

The yield question after the CLARITY Act

The GENIUS Act became law on 18 July 2025 and set a federal framework for payment stablecoins, digital tokens whose issuer is obliged to redeem them for a fixed amount of money. It bars issuers from paying holders interest or yield for simply holding the token, and leaves most of the operating detail to federal regulators. Congress then tried to pass a broader market structure bill, the CLARITY Act, which would also have set limits on the rewards crypto platforms pay on stablecoin balances. That bill fell 49 to 50 in the Senate on 15 September 2026.

The question of stablecoin rewards therefore rests on the GENIUS Act’s issuer ban and on the agencies writing its rules. The Act splits that work among several federal agencies, each covering the issuers under its jurisdiction. The OCC, which charters and supervises national banks, chose to finalise its part without waiting for a joint rule with the others, and says it will keep coordinating with them.

What the OCC’s final rule covers

The OCC’s bulletin states that the rule applies to national banks, federal savings associations and federal branches of foreign banks together with their subsidiaries, to nonbank companies seeking approval as federal issuers, to foreign issuers, and to certain state issuers under the agency’s authority. It creates a new part of the Code of Federal Regulations (CFR), 12 CFR part 15, covering reserves, redemption, risk management, audits, custody, capital and licensing. The OCC received about 328 comments on its proposal from crypto companies, banks, trade groups, non-profit organisations, academics and individuals. Rules on the Bank Secrecy Act, anti-money laundering and sanctions will follow in a separate rulemaking with the Treasury Department.

The OCC says its changes to reserve management give issuers more flexibility while keeping the core liquidity and diversification requirements. Issuers must generally meet redemption requests within two business days, and the rule now defines a business day as any day except a Saturday, Sunday or federal holiday. Issuers may also sell Treasury bills maturing in 93 days or less through repurchase agreements to raise cash for redemptions.

A buyer on an exchange is not yet the issuer’s customer

The proposal defined a customer as anyone who buys the products or services of another person, and several commenters warned that this could reach people with only an indirect link to the issuer. The final rule text narrows it to someone who buys directly from the issuer, or who asks the issuer directly to convert, redeem or repurchase a stablecoin. A holder who bought the token from an exchange, or from a distributor selling it under its own brand without acting as the issuer’s agent, becomes the issuer’s customer only when they seek redemption or buy something else from the issuer directly. The OCC says the change gives issuers a set of customers they can easily identify.

The definition decides who is owed the information protection and notification duties in the OCC’s rule, and it leaves the meaning of customer under privacy laws and the Bank Secrecy Act untouched. Someone keeping stablecoins in an app deals with the app until the day they decide to redeem.

The same line runs through identity checks

Five federal agencies drew the same boundary in June, in a customer identification proposal that would require issuers to verify the people who open accounts with them directly and leaves secondary-market holders outside the requirement. The two texts, read together, describe a regulated issuer that knows the businesses and individuals at its own counter. Everyone else reaches the token through the platform that sold it to them.

The holder the yield ban refers to

The GENIUS Act bars an issuer from paying interest or yield to a holder solely for holding, using or retaining its payment stablecoin. The statute does not say whether a holder is whoever controls the token or whoever owns it, and the OCC settled the point by defining a payment stablecoin holder as the beneficial owner. A token can sit at an address on a blockchain controlled by a custodian acting for a client, and the definition separates that custodian from the client who would benefit economically from any interest. The final rule then writes the defined term directly into the yield prohibition, in place of the undefined wording the proposal had taken from the statute.

The presumption the OCC dropped

The proposal included a rebuttable presumption that certain transactions between an issuer and its affiliates or related third parties broke the yield ban, which would have put the burden on the issuer to show otherwise. Commenters split on it. Some wanted the presumption broadened or replaced with an outright ban on indirect payments, and others wanted it narrowed or removed because it could catch payments made for reasons other than holding the token.

The final rule removes the presumption. It also declines to presume that rewards programmes created before the GENIUS Act comply with it, noting that Congress could have written a safe harbour for them and did not, so older programmes will be evaluated the same way as new ones. There is no exemption for very small payments and no general safe harbour, and the OCC says the facts of each decentralised finance (DeFi) arrangement may weigh heavily on whether it was set up to evade the ban.

Payments for bona fide services would generally fall outside the ban, the OCC says, unless other facts point the other way, because they are not paid solely for holding a stablecoin. The rule also bars issuers from any activity the OCC determines is an evasion of the Act’s issuer requirements or of the rule itself.

The ABA welcomed parts of the rule and disagrees with this change. Its president and chief executive, Rob Nichols, said in a statement reported by the ABA’s Banking Journal that removing the proposed safeguards lets issuers provide yield that is economically equivalent to interest while technically avoiding the prohibition.

The platforms between issuer and holder

The presumption targeted issuers’ dealings with affiliates and related third parties, a group that can include the platforms standing between an issuer and the people holding its tokens. OKX’s stablecoin rewards show how such arrangements work: in early October the exchange, as the platform, paid US customers up to 3.5% on Global Dollar (USDG), and the Global Dollar Network says it returns up to 100% of reserve income to the platforms that distribute the token. An arrangement of that kind, where the issuer falls under the OCC, will now be judged on its facts, with no presumption that it breaks the ban and no protection for programmes that began before the Act.

What changes for fintech companies and their users

Fintech companies that distribute stablecoins now have a federal text that sets out where the issuer’s obligations sit: reserves, redemption at par, generally within two business days, and the customers who come to the issuer directly. A token from an OCC-supervised issuer has that issuer’s redemption obligation behind it, whichever app sold it. The OCC will announce separately when it begins accepting applications from would-be issuers, and it expects to update the rule as the business develops and its supervisors gain experience.

A person will be able to hold a federally supervised digital dollar from 18 January 2027 without ever becoming the issuer’s customer, and the question the yield ban asks about the rewards they collect is whether the issuer, directly or through someone else, is paying them simply for holding the token.

Editor’s note

Every piece goes through careful verification, but mistakes can happen. Readers who spot an error or have additional information can write to rosalia@thebrightminded.com.