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ARTICLE · 05 NOVEMBER 2026

OCC Finalizes GENIUS Act Rulemaking

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The Office of the Comptroller of the Currency has finalized comprehensive regulations implementing the GENIUS Act, establishing a federal framework for payment stablecoin issuers. The Final Rule addresses reserve requirements, redemption timelines, capital standards, and operational safeguards while providing greater flexibility than initially proposed in areas such as reserve diversification, white-label arrangements, and foreign exchange risk management.

United StatesFinance and Banking
David Beam
David Beam
Matthew Bisanz
Matthew Bisanz
Joseph A. Castelluccio
Joseph A. Castelluccio
Andrew Hartlage
Andrew Hartlage
Anna T. Pinedo
Anna T. Pinedo
Andrew Olmem
Andrew Olmem
Jeffrey P. Taft
Jeffrey P. Taft
Kelly F. Truesdale
Kelly F. Truesdale
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On October 21, 2026, the Office of the Comptroller of the Currency (“OCC”) issued a final rule implementing the Guiding and Establishing National Innovation for US Stablecoins Act (the “GENIUS Act”) for payment stablecoin activities under its jurisdiction (the “Final Rule”). The Final Rule largely retains the framework from the OCC’s proposal announced on February 25, 2026 (the “Proposal”), discussed in our previous Legal Update, but changes the reserve, redemption, and capital requirements in important respects. The Final Rule takes effect on January 18, 2027.

This Legal Update reviews key features of the Final Rule, following the structure of new 12 C.F.R. Part 15, with a focus on the principal changes from the Proposal and their implications for US and non-US issuers.

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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