OCC's final rule to start fresh in weighing stablecoin rewards against GENIUS Act ban

The U.S. Office of the Comptroller of the Currency (OCC) issued a final rule regarding stablecoin operations and third-party exchange relationships, set to go live in January. The agency will evaluate reward programs on a case-by-case basis under the GENIUS Act, noting that the statutory ban targets rewards made strictly for holding stablecoins.
Why it matters
Regulatory clarity from the OCC shapes how stablecoin issuers and banks operate in the United States, directly affecting compliance standards and consumer rewards structures.
The OCC, which oversees U.S. national banks and trusts that will play a central role in the issuance of stablecoins under the law, issued a final rule on Wednesday to establish the regulations under which the firms that issue the dollar-based tokens will operate — including in their third-party relationships with the exchanges on which their stablecoins change hands.
The agency — an independent bureau of the Treasury Department — has declined to offer examples or illustrations of what type of rewards operations may run afoul of the GENIUS Act, which declared that payments to customers made "solely in connection with the holding, use, or retention of such payment stablecoin" won't be allowed. The industry, which won't get any safe harbors for existing programs, will just have to test the agency's case-by-case oversight to get a better sense of the rule, which is set to go live on January 18.
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