A stablecoin can promise a dollar on demand. The harder question is whether its issuer can deliver when customers want out. The OCC’s payment-stablecoin action addresses reserves and redemption readiness, but the official materials dated February 25 and March 2, 2026, describe a proposed rule, not a final one.
- Status: The OCC issued a notice of proposed rulemaking.
- Main focus: Eligible reserves, redemptions and issuer oversight.
- Still unresolved: The proposal offers two approaches to reserve diversification.
In OCC Bulletin 2026-3, dated February 25, 2026, the Office of the Comptroller of the Currency said it was proposing regulations to implement parts of the GENIUS Act. A Federal Register notice dated March 2, 2026 also sets out proposed provisions. These official materials describe a proposal. They do not confirm whether a final rule was issued later.
The distinction matters. Enacted on July 18, 2025, the GENIUS Act establishes the statutory framework for payment stablecoins. The OCC proposal would explain how parts of that framework apply to institutions and issuers under the agency’s jurisdiction. Its proposed details are not final requirements, and the materials cited here do not establish a final effective date or compliance deadline.
Who could fall under the OCC proposal?
The proposal applies to defined categories, not every stablecoin company or crypto business. The OCC lists national banks and their subsidiaries, federal savings associations and their subsidiaries, federal branches, certain foreign issuers, and some nonbank or state-qualified issuers seeking or holding federal qualified-issuer status. The requirements would depend on the entity and the Act’s terms.
For example, a national bank subsidiary that issues a payment stablecoin may fall under the OCC’s authority. A software provider building stablecoin infrastructure is not automatically subject to direct OCC supervision just because it works in the sector.
The proposal would address what covered issuers may do, how they hold reserves, how they handle redemptions, and how they manage and report risks. It also covers oversight, custody, applications and registrations, including matters involving certain foreign and state-qualified issuers. The broader statutory framework may also involve other agencies and separate rulemakings. The OCC’s proposed federal rulebook is one part of that process.
What could count as a reserve?
Reserves are the assets an issuer holds to back its outstanding stablecoins and meet redemption requests. The Federal Register proposal lists potential eligible assets, including U.S. currency and balances at a Federal Reserve Bank; certain deposits or insured shares at insured institutions; and Treasury bills, notes or bonds with 93 days or less remaining to maturity.
The short maturity limit matters because shorter-term Treasuries generally face less price volatility from changing interest rates than longer-dated bonds. But they are not cash. An issuer may still need to sell or otherwise convert them to meet a sudden surge in redemptions.
The proposal also lists certain overnight repurchase and reverse-repurchase agreements backed by qualifying Treasury securities. In a repurchase agreement, one party effectively borrows cash against securities and agrees to buy them back. A reverse-repurchase agreement describes the transaction from the other side. The overnight term limits how long the arrangement runs, while the Treasury collateral is intended to protect the cash provider’s position.
Other proposed categories include registered government money-market funds invested solely in eligible assets, and certain similarly liquid assets issued by the federal government if the OCC approves them. A qualifying money-market fund can provide access to a pool of short-term assets, but it would have to meet the proposal’s stated conditions. Having “government” in its name would not be enough.
The proposal would allow certain eligible reserve assets to be held in tokenized form, subject to applicable laws and regulations. Tokenization means representing an asset digitally on a blockchain or similar system. It can change how an asset is recorded or transferred, but it does not settle questions about legal ownership, custody, access or the ability to turn the asset into cash.
The proposal would also limit withdrawals of reserves that exceed outstanding stablecoin issuance. Before making such a withdrawal, an issuer would need the required monthly examination and certification and would have to publish the related disclosure. The reserves left after the withdrawal would still need to cover outstanding issuance.
Redemption readiness is an operational test
A reserve may look liquid on a balance sheet and still be difficult to turn into cash quickly under stress. The OCC proposal asks whether issuers have the procedures, personnel and reliable channels needed to convert reserve assets in time to meet redemptions.
In some cases, the proposal says test transactions could help show that those processes work, particularly when operations are complicated or rely on channels the issuer rarely uses. The OCC also warns that suddenly using an unfamiliar funding route during market stress could alarm investors. An issuer that demonstrates its capabilities through ordinary activity, such as regular redemptions, would not necessarily need extra test transactions.
This is the OCC’s proposed approach, not a final supervisory standard. The practical question is whether an issuer can convert eligible assets and process redemptions reliably when demand rises, not just whether its reserve list looks reassuring in normal conditions.
Reserve diversification remains undecided
The proposal offers two possible approaches to reserve diversification. One would set a principles-based standard and offer an optional quantitative safe harbor, a numerical route issuers could use to demonstrate compliance. The other would impose quantitative requirements directly. The proposal says only one approach would be selected for the final rule.
That choice could determine how much flexibility issuers have and how clearly they can measure compliance. It is one of several details still open as the rulemaking proceeds.
What about anti-money-laundering rules?
The OCC says Bank Secrecy Act, anti-money-laundering and Office of Foreign Assets Control sanctions requirements fall outside this rulemaking. They would be addressed separately in coordination with the Treasury Department. That does not exempt stablecoin issuers from obligations under existing or separate laws.
Key questions about the OCC stablecoin proposal
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Did the OCC issue a final rule?
The OCC bulletin and Federal Register notice, dated February 25 and March 2, 2026, respectively, describe a proposed rule. They do not establish whether a final rule followed later.
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What would the proposal cover?
It would set out OCC rules for specified institutions and issuers, including provisions on reserves, redemptions, oversight and reporting.
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What reserves could qualify?
Proposed categories include cash, certain deposits, short-term Treasury securities, qualifying government money-market funds and other eligible assets.
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Does it cover every stablecoin company?
No. Coverage depends on the issuer’s status and how the Act applies to it. A crypto-related business is not automatically under direct OCC supervision.
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What reserve-diversification approach will apply?
The proposal presents two alternatives: a principles-based standard with an optional quantitative safe harbor, or direct quantitative requirements. It says one approach would be chosen for the final rule.
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When would compliance begin?
The cited proposed-rule materials do not establish a final effective date or compliance deadline.
The proposal’s focus on reserve backing also raises questions about deposits and how stablecoin rules could affect them. For consumers managing payment methods and recurring charges, payments and subscriptions offer a familiar example of services that depend on reliable payment rails.