OCC Finalises GENIUS Act Stablecoin Rules With Softer Reserve and Yield Terms
Key points
- The OCC's final GENIUS Act stablecoin rules were published on 21 October 2026 and take effect on 18 January 2027, running to more than 700 pages.
- The daily liquidity requirement was cut from the February proposal's 10% to 5%, and the potential 30% weekly liquidity requirement has been eliminated entirely.
- The weighted average maturity cap of 20 days has been dropped, allowing issuers to hold the bulk of reserves in Treasuries with maturities up to 93 days if their own liquidity risk assessment supports it.
- A proposed 50% single-institution cap on daily liquidity exposure has been removed, and the retained 40% broad concentration limit now carries exclusions for government exposures, centrally cleared repo, self-held assets, and qualifying custodians.
- Issuers are explicitly permitted to custody 100% of their own assets, though Treasury holdings make some third-party involvement practically unavoidable.
The Office of the Comptroller of the Currency (OCC) published its final stablecoin regulations under the GENIUS Act on 21 October 2026, with the rules taking effect on 18 January 2027. The finalised framework walks back several of the more stringent requirements floated in the OCC’s February proposals, easing both liquidity ratios and concentration limits in ways that materially widen the operational latitude available to stablecoin issuers.
On the liquidity side, the February proposal’s 10% daily liquidity floor has been halved to 5%, while a potential 30% weekly liquidity requirement has been dropped altogether. The weighted average maturity cap of 20 days has also been removed, meaning an issuer could in principle hold 5% of reserves in daily-liquid instruments and the remaining 95% in Treasuries with maturities out to 93 days, provided the issuer’s own liquidity risk assessment supports that positioning. Where portfolios are weighted toward Treasuries, access to repo markets offers an additional liquidity channel, contingent on normal market conditions.
The concentration rules have been loosened in a parallel direction. A proposed 50% single-institution cap on daily liquidity exposures has been removed entirely, and while the broader 40% single-institution exposure limit has been retained, a set of exclusions now applies to government exposures, centrally cleared repo, self-held assets, and qualifying custodians. The final rule makes explicit that an issuer may custody 100% of its own assets, though issuers holding Treasuries will in practice still require third-party involvement. Yield, which may attract more attention, appears to be the secondary story here; reserve maturity flexibility is the more consequential departure from the February draft.