The OCC finalized its rules implementing the GENIUS Act on October 21. The rules cover permitted payment stablecoin issuers and foreign payment stablecoin issuers under OCC jurisdiction. They also cover certain custody activities by banks the OCC supervises. “The final rule and the GENIUS Act take effect on January 18, 2027,” the release says. The OCC will announce separately when it begins accepting applications and waiver requests.
The rule leaves one piece for later. Requirements tied to the Bank Secrecy Act, anti-money laundering and OFAC sanctions will come in a separate rulemaking developed with Treasury. Comptroller Jonathan V. Gould said the rule provides “a clear, practical framework for payment stablecoin innovation” with standards for reserve backing, redemption and risk management. Three bulletins carry the detail. Bulletin 2026-50 is the rule, 2026-51 covers waivers and applications, and 2026-52 revises the reporting forms.
The pitch to community banks
Gould spoke to the Ohio Bankers League on October 27. He said “there is a pathway for interested community banks to explore issuing payment stablecoins through a subsidiary.” He also said “the rule applies the same standards to bank and nonbank issuers.” The OCC published a community bank fact sheet on the Act alongside the speech.
- Oct 21OCC final rule issuedBSA, AML and sanctions rules come separately.
- Oct 27Comptroller describes the subsidiary path
- Dec 8NCUA Call Report comments closeA new Payment Stablecoin Activities schedule is proposed.
- Jan 18Rule and GENIUS Act take effect
- Mar 2027First credit union Call Report cycle with the schedule
Credit unions will report it
The NCUA proposed Call Report changes for the March 2027 cycle on October 16. “This quarter’s proposed changes include adding a new schedule for Payment Stablecoin Activities,” the agency said. Comments close on December 8. A credit union that holds, custodies or facilitates stablecoins will need data for that schedule within months of the Act taking effect.
A stablecoin program at a community bank now has a rulebook and a date. The BSA chapter of that rulebook is still unwritten.
- Ask your board whether stablecoin issuance or custody belongs in your strategy before January 18. If it does, read Bulletin 2026-51 on applications first.
- Plan your BSA and sanctions controls for any stablecoin activity now. The separate Treasury rulemaking may arrive after the rule takes effect.
- Credit unions should check whether their systems can produce the data for the proposed stablecoin schedule and comment by December 8 if they cannot.
Zovos maps each new rule to the policies, controls and owners it touches. A stablecoin pilot then starts with a list of the obligations it inherits.
This is for information only and is not legal advice. Confirm your obligations under the GENIUS Act with counsel before acting.