According to Woofun AI, on October 21, 2026, the US Monetary Commission (OCC) officially promulgated the final rules of the GENIUS Act, marking the substantial implementation of the federal banking regulatory framework in the stablecoin field. The core controversy of this rule focuses on the stablecoin yield plans of leading exchanges such as Coinbase (COIN.US). The OCC removed strict provisions on “a third party paying interest on behalf of the issuer is presumed to be illegal” in the final draft, while clearly refusing to provide a safe haven of compliance for relevant platforms, leaving the right to determine the legality of earnings in a vague case-by-case review.
This 700-page regulatory document is the first core rule of the GENIUS Act to be completed by a federal bank regulator. The detailed processing reflects the difficult balance between innovation and risk on the part of the regulatory authorities. According to data compiled by Woofun AI, the current income level of mainstream stablecoins in the market is significantly higher than traditional bank savings: Coinbase One's USDC rewards are about 3.75%, PayPal (PYPL.US)'s PYUSD is about 4%, and Kraken's USDG can reach up to 4.5%, while the average savings interest rate for US savings accounts during the same period was only 0.38%.
Despite the huge spread, the OCC did not directly determine that these benefits were illegal, but instead defined the boundaries by reconstructing legal logic. An attempt was made at the proposal stage to establish a “rebuttable presumption”, that is, if a related party or third party pays interest on the issuer's behalf, it is first assumed that the violation was violated, and the parties concerned were able to prove and refute it; however, the final draft removed this provision on the grounds that “the market is still in its early stages,” and this withdrawal can easily be interpreted as regulatory relaxation.
However, the document also clarifies a number of key restrictions: existing incentive programs are not protected by a 'grandfather clause'; Congress was aware of the existence of these plans when legislating, which is not equivalent to approving their compliance; DeFi (decentralized finance), white label arrangements, and micropayments are not exempt from categories, and the OCC emphasizes that “interest with a different name is still interest.” In terms of authority boundaries, the OCC clearly limits its jurisdiction to payment stablecoin issuers, some foreign issuers, and custodian businesses within its jurisdiction. It does not directly license exchanges. Restrictions on platforms such as Coinbase and Kraken are indirectly transmitted through relationships between licensed issuers and third parties. The original text of the bill prohibits issuers from paying interest to holders 'only for holding, using, or retaining payment stablecoins'. The final draft breaks this ban down into two core variables: payer and reason for payment. If the money is paid by the issuer itself, and the reason is only “holding tokens,” then it is prohibited; if it is paid by a related party or exchange, but the essence is still only related to holding, it may also be considered an evasive act. Conversely, payments may be exempted if at least part of the payment is for transaction incentives, real service, or other independent reasons.
This shift transformed legislative principles into complex factual judgments, and while removing presumptions reduced the issuer's burden of proof, it did not bring certainty. The OCC reserves anti-circumvention rights and can re-apply the law according to specific facts. The flexibility of the rules itself is a regulatory position.
The multi-party game surrounding the characterization of rules unfolded rapidly, reflecting deep differences in the industry over the direction of regulation. Rob Nichols, president and CEO of the American Bankers Association, harshly criticized in a statement, arguing that the final draft deviates from the original proposal and is tantamount to maintaining the status quo of crypto platforms and contrary to Congress's intention to protect local lending. He pointed out that issuers can still use related parties or exchanges to provide 'economic equivalent benefits', thereby removing deposits from the banking system and weakening the foundations of the traditional banking industry. In contrast, Coinbase Chief Policy Officer Faryar Shirzad believes that the rules strictly follow the interpretation of congressional texts and set capital requirements according to actual risk, creating a durable framework for US dollar stablecoins.
Circle's (CRCL.US) Chief Strategy Officer Dante Disparte is also optimistic, saying this is a transformation of legislative leadership into clear, enforceable regulatory standards. Jaret Seiberg, head of Washington research at TD Cowen (TD.US), is more calm. He believes this is negative for banks because the platform's ability to pay earnings has not been completely cut off. Case-by-case reviews create uncertainty, and ultimately it may be necessary to rely on the Supreme Court to define what benefits are legitimate. The essence of the tripartite dispute is: is the third party reward a competitive space deliberately left by the National Assembly, or should it be presumed to be an evasive act? The OCC chose neutrality and pushed the answers to subsequent implementation.
The schedule for implementing the rules and the gap between agencies will be key variables in the future. As of January 18, 2027, it is generally a criminal offense to issue payment stablecoins without permission. Existing US issuers can apply for an exemption of up to 12 months. The OCC says it generally favors approval, unless there is a stronger reason to refuse, but the application window is not yet open and the relevant information collection plan is approved. The review criteria for the first batch of licenses will be the first real signal. If the OCC includes the trading platform's reward arrangement in the 'only for holding' test during the review, those 4% of products will face a specific ruling. Another challenge comes from the mixed voices among agencies: the corresponding rules of the Federal Reserve and FDIC have yet to be finalized, and both have included similar presumptive clauses in their previous proposals. If the standards of the three regulators are inconsistent, compliance costs and arbitrage space will be reshuffled.
Furthermore, the Clarity Act failed to advance in the Senate in September 2026, and related disputes may still return through litigation or new legislation. The rule only covers the OCC jurisdiction. The rest of the ecosystem is handled separately by two other agencies and the Ministry of Finance's anti-money laundering and sanctions rules, and the overall regulatory puzzle is still incomplete.