OCC Rules for Stablecoin

The GENIUS Act, signed July 18, 2025, put every insured depository institution on the same clock but not under the same rulebook. The OCC proposed its framework on February 25, 2026, for national banks, federal savings associations, and their subsidiaries. The FDIC followed in April 2026 for the institutions it supervises, tracking the OCC in most places but differing on reserve concentration, on the operational backstop and automatic liquidation, on affiliate transactions with an issuing subsidiary, and, in the provision community bankers should read first, stating that deposit insurance does not depend on the technology or recordkeeping used to record a deposit liability. The Federal Reserve has still not proposed a rule for state member banks. The agencies missed the one-year deadline of July 18, 2026, which leaves the statutory effective date of January 18, 2027, in control.

This session will be the community bank read on the stablecoin rules. It will cover what the OCC framework requires and where the FDIC proposal differs, so every banker in the room can find the column that applies to their charter: application and approval, one-to-one reserves and eligible assets, capital and the operational backstop, redemption at par, disclosure and certification, and the prohibition on paying interest or yield that the industry is still fighting over. Then, the part that applies whether or not your bank ever issues a token: how tokenized deposits are treated, what to make of the offers already arriving from cores, fintechs, and consortiums, what custody actually involves, and what to have documented before January 18, 2027. Attendees will leave with a decision tree covering the five realistic paths and a checklist for the board conversation.

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