The OCC Just Showed Us What Stablecoin Regulation Actually Looks Like: 376 Pages of It

From Blueprint to Construction Manual

The GENIUS Act was signed into law on July 18, 2025. Eight months later, the Office of the Comptroller of the Currency has published a 376-page Notice of Proposed Rulemaking that translates that statute into operational reality. If the GENIUS Act was the blueprint, this NPRM is the construction manual.

This analysis reads the entire 376-page document and distills what you need to know — the bar is high, but it's clear, deliberate, and draws on decades of bank supervision experience.

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What You'll Learn

• Reserve Asset Requirements — The conservative list of permissible reserves (T-bills, deposits, money market funds — no corporate bonds or crypto), fair value accounting, and two competing diversification frameworks
• The 10/30/40/20 Rule — How the safe harbor for reserve diversification works in practice, with a worked example for a $20 billion issuer
• Two-Business-Day Redemption — The mandatory redemption timeline with a 10% circuit breaker for stress events
• No Interest, No Rehypothecation — How the OCC closes workarounds on prohibited yield payments and reserve reuse
• Capital Requirements — The individualized approach starting at 2.5% of outstanding issuance, modeled on national trust bank supervision
• Custody Standards — Bank-grade requirements for private key management, segregation, and blockchain-specific due diligence
• The Application Process — What it takes to get an OCC charter as a Federal qualified payment stablecoin issuer
• Risk Management — Internal controls, audit, IT security, and incident response standards drawn from existing bank supervision frameworks

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Key Numbers

Requirement	Threshold
Reserve backing ratio	1:1 minimum (fair value)
T-bill maximum maturity	93 days
Immediate liquidity (safe harbor)	10% of reserves
5-day liquidity (safe harbor)	30% of reserves
Max concentration per institution	40% of reserves
Weighted average maturity cap	20 days
FDIC-insured deposit floor	3% (up to $500M)
Redemption deadline	2 business days
Stress redemption circuit breaker	10% in 24 hours
Minimum capital ratio	2.5% of outstanding issuance

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Who Should Read This

Existing Stablecoin Issuers

This NPRM is a roadmap for what compliance will look like if you seek an OCC-supervised charter. The reserve, redemption, and capital requirements are more detailed than anything the industry has operated under to date.

New Market Entrants

A clear — if demanding — set of requirements for anyone considering entering the stablecoin market through a federal charter.

Banks Considering Stablecoin Activities

National banks and Federal savings associations that want to issue stablecoins through subsidiaries or provide custody services for stablecoin reserves will find their specific requirements detailed here.

Compliance and Legal Teams

The risk management standards, reporting obligations, and examination framework are drawn directly from existing bank supervision practices — but adapted for stablecoin-specific risks.

Crypto Custody Providers

The custody subpart creates specific requirements for any institution holding stablecoin reserves, private keys, or related assets under OCC supervision.

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The Clock Is Running

The comment period is 60 days. The GENIUS Act's effective date is the earlier of 18 months after enactment (January 2027) or 120 days after final regulations are issued.

The era of stablecoins operating in a regulatory gray zone is ending. Download the full analysis to understand every provision and prepare your organization.

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Analysis published March 18, 2026