What the OCC’s final GENIUS Act rule means for national trust charters, permitted payment stablecoin issuers, and the path to January 18, 2027.
On July 18, 2025, the President of the United States signed the Guiding and Establishing National Innovations for U.S. Stablecoins Act known as the GENIUS Act which established the first comprehensive federal regulatory framework for payment stablecoins. It aims to promote innovation, ensure 1:1, U.S. dollar-backed reserves, and authorize both bank and nonbank entities to issue stablecoins under strict supervision.
The GENIUS Act names the Office of the Comptroller of the Currency (OCC) as a primary supervisor for permitted payment stablecoin issuers (PPSIs). The OCC is responsible for licensing, and regulating, and supervising nonbank issuers, national bank subsidiaries, and foreign entities.
On October 21, 2026, the OCC issued its final rule implementing the GENIUS Act for permitted payment stablecoin issuers and foreign payment stablecoin issuers under its jurisdiction, as well as certain custody activities conducted by OCC-supervised entities. The final rule and the GENIUS Act take effect on January 18, 2027. Bank Secrecy Act, anti-money laundering, and Office of Foreign Assets Control (OFAC) sanctions requirements will be addressed in a separate rulemaking in coordination with the Department of the Treasury. The OCC will announce in a separate news release the date for accepting and processing applications and waiver requests from prospective permitted payment stablecoin issuers.
Key dates
A national trust bank charter is a specialized federal business license issued by the OCC, authorizing institutions to operate nationally as fiduciaries and provide services like custodial, safekeeping, and settlement. These entities are generally restricted from taking demand deposits or making traditional loans, and are not required to be insured by the FDIC, though they must abide by National Bank Act. This makes it a great fit for crypto firms seeking to provide custody and asset management services.
In summary, a charter includes:
|
Feature |
Description |
|
Federal Authority |
Allows operations across all US states under a single federal supervisor (the OCC), bypassing the complex and expensive state-by-state licensing process. |
|
Permissible activities |
Focused on fiduciary services such as digital asset custody, clearing, settlement, and staking. |
|
Key restrictions |
These banks cannot take FDIC-insured deposits or engage in general commercial lending, separating their activities from traditional banking. |
|
Regulatory standing |
Provides a "gold standard" of federal oversight, significantly increasing credibility with institutional investors and partners. |
Prior to the GENIUS Act, there were 60 national trust banks, and since the signing of the Act, nearly 40 de novo applications have been filed (thru the end of August 2026).
On February 25, 2026, the OCC published a notice of proposed rulemaking to implement the GENIUS Act; that proposal appeared in the Federal Register on March 2, 2026. After considering approximately 328 comments from crypto-focused companies, banks, trade groups, academics, and others, the OCC issued its final rule on October 21, 2026 (OCC News Release 2026-92; OCC Bulletin 2026-50), with Federal Register publication on October 23, 2026.
The final rule establishes requirements for permitted payment stablecoin issuers and foreign payment stablecoin issuers under the OCC’s jurisdiction, as well as certain custody activities conducted by OCC-supervised entities. It addresses all regulations the OCC is required to promulgate under the GENIUS Act, except those related to the Bank Secrecy Act, anti-money laundering, and OFAC sanctions, which remain on a separate Treasury-coordinated track. The OCC will continue to coordinate with other agencies responsible for implementing aspects of the GENIUS Act.
Relative to the proposal, the final rule provides more flexibility on reserve asset management while retaining core liquidity, diversification, and concentration requirements; adds clarity on permitted activities, redemption, and risk management; clarifies supervision, custody, and licensing and registration; and includes capital and operational backstop requirements that are more detailed than, but consistent with, the proposal.
The majority of the GENIUS Act OCC rules are addressed in a new 12 CFR 15, which will include standards and requirements related to the following:
The rule revises the capital adequacy standards in 12 CFR 3, prompt corrective action regulations in 12 CFR 6, assessment of fees in 12 CFR 8, and rules of practice and procedure in 12 CFR 19.
The OCC granted conditional approvals to a growing list of firms, including Bridge (Stripe), BitGo, and Paxos. Once conditional approval is granted, the firm has one year to stand up the bank which includes passing a full examination. Several banks have passed all requirements and have opened their doors for business, including Erebor and more recently Ripple and Circle.
The opportunity goes beyond crypto firms such as:
With the final rule now issued, the challenge shifts from interpreting a proposal to implementing operable frameworks before January 18, 2027.
The creation of the infrastructure is complex, and it must not impact your compliance with the rules and regulations. At Regnology, we serve both the regulated and the regulators. Our solutions are built to solve these exact challenges.
We provide a single, unified platform that automates the entire regulatory lifecycle, from data aggregation to final report submission. We offer Risk, Finance, and Reporting solutions that include capital, liquidity, general and sub-ledgers, consolidation, and various federal reporting requirements.
Ready to learn more? Contact a Regnology expert today, and let's discuss your path to becoming a federally compliant financial institution.
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