Stablecoin Issuers Will Face Clearer Regulatory Requirements
The GENIUS Act was signed into law in July 2025, with the goal of establishing a federal regulatory framework for U.S. payment stablecoins.
The final rules announced by the OCC this time mainly target permitted payment stablecoin issuers within its regulatory scope, certain foreign payment stablecoin issuers, and related custody activities conducted by institutions under its supervision.
The rules cover reserve assets, redemption arrangements, risk management, audit reports, regulatory review, capital requirements, and application and registration, among other matters.
For stablecoin issuers, the future will require attention not only to issuance scale and market demand, but also to building reserve management, redemption, and risk control systems that can meet regulatory requirements. Compliance capability will become an important condition for business expansion.
However, it should be noted that this does not mean all stablecoin issuers will automatically obtain U.S. regulatory approval. Companies still need to determine whether they need to apply for the corresponding qualifications based on their own business, place of registration, and applicable regulatory framework.
Stablecoins Cannot Pay Interest Directly—What About Trading Platform Rewards?
The most noteworthy controversy in these rules comes from the stablecoin yield mechanism.
The GENIUS Act restricts payment stablecoin issuers from directly paying interest or yield to holders. Its policy logic is to distinguish payment stablecoins from traditional bank deposits and prevent stablecoins from directly becoming a substitute for bank deposits without the same regulatory safeguards.
However, yield mechanisms in the market are not limited to issuers paying interest directly.
For example, trading platforms may provide rewards to users holding stablecoins through membership rewards, cooperative arrangements, or other mechanisms. Such arrangements involve relationships among issuers, trading platforms, and third parties, making the regulatory boundary complex.
According to The Block, the OCC's final rules did not retain the presumption-of-violation provisions in the previous proposal targeting certain third-party arrangements. Regulatory officials said such arrangements need to be judged on a case-by-case basis; if there is obvious behavior evading legal restrictions, regulators still retain enforcement space.
This does not mean trading platforms can pay stablecoin interest to users without restrictions. More accurately, issuers paying interest directly and third-party platforms providing rewards are not entirely the same in regulatory judgment, and specific arrangements may still be subject to review.
Why Does the Disagreement Between Banks and Crypto Platforms Still Exist?
The dispute over stablecoin yield actually concerns where funds ultimately flow.
For crypto platforms, stablecoin rewards can help attract users, retain funds, and improve competitiveness in trading and payment businesses. If users can also receive rewards for holding stablecoins, platforms have the opportunity to build stronger user stickiness in businesses such as trading, payments, and asset management.
Banks worry that stablecoins and platform reward mechanisms may attract funds originally held in bank accounts, thereby affecting banks' deposit base and lending capacity.
The core of the debate between the two sides is not just whether users can obtain yield, but whether stablecoins can provide economic returns similar to deposits without fully replicating the bank deposit regulatory system.
The OCC's final rules this time did not make a blanket presumption-of-violation judgment on all third-party reward arrangements, but regulators still emphasized the need to prevent behavior that evades legal restrictions. As the market develops, the relevant boundaries may still be further adjusted.
Who Might Benefit from the New Rules?
From an industry perspective, gradually clearer rules help companies assess the compliance costs of entering the U.S. market and also provide traditional financial institutions and crypto companies with a clearer business framework.
First, stablecoin issuers that meet regulatory requirements are expected to establish clearer market expectations in terms of reserve transparency, redemption capacity, and risk management.
Second, trading platforms need to reassess stablecoin rewards, user incentives, and cooperative arrangements with issuers. Whether reward mechanisms can continue depends not only on the business model but also on whether the specific design complies with applicable law.
In addition, competition between banks and stablecoin companies will not end because the rules are announced. Regulatory implementation may reduce some legal uncertainty, but it will not automatically eliminate disputes over fund flows, user protection, and financial stability.
The Stablecoin Industry Enters the Implementation Phase, and the Real Changes Are Still Ahead
The final rules released by the OCC this time are scheduled to take effect on January 18, 2027. Matters related to anti-money laundering, the Bank Secrecy Act, and sanctions will still be handled through subsequent rulemaking, and other regulators will also continue to advance the implementation work for which they are responsible.
Therefore, it is too early to assert now that the U.S. stablecoin market has been fully opened, or that exchange reward mechanisms have obtained a clear exemption.
What is more noteworthy is that stablecoin regulation is moving from principled legislation to specific issues such as reserves, redemption, auditing, custody, and yield mechanisms. In the future, market competition may no longer be just about which stablecoin has stronger liquidity and covers more chains, but also about who can continue to provide reliable payment and financial services under compliance requirements.
For the crypto industry, the gradual formation of a regulatory framework does not mean competition is over, but rather that the stablecoin business is entering a stage that places greater emphasis on compliance capability, fund management, and business sustainability.
