The GENIUS Act Gets Its Rulebook: What Stablecoin Issuers Must Do Now

On February 25, 2026, the OCC published its proposed rulemaking to implement the GENIUS Act — the US federal framework for payment stablecoins.

The key obligations for any entity wishing to issue a payment stablecoin in the US:

**Reserves:** 1:1 backing at all times. Reserve assets are restricted to US coins and currency, Fed accounts, T-bills with ≤93 days maturity, overnight repo agreements, and government money market funds. No corporate bonds. No crypto.

**Liquidity:** Two options — principles-based diversification (Option A) or hard quantitative floors (Option B): at least 10% in daily liquid assets, at least 30% in weekly liquid assets, no more than 40% concentration at any single institution.

**Transparency:** Monthly public disclosure of reserve composition, certified by CEO and CFO, examined by a registered public accounting firm.

**Enforcement:** If reserves fall short for 15 consecutive days, mandatory redemption of all outstanding stablecoins begins automatically.

For issuers above $25 billion outstanding, an additional 0.5% (capped at $500M) must be held as insured deposits.

This is not a light-touch framework. It is bank-grade infrastructure applied to stablecoin issuance.

If you are building a stablecoin product or advising one, the comment period is open now.