Investors and firms holding or distributing stablecoins face a clearer picture of the first federal stablecoin regime after seven US agencies spent the past seven months publishing their GENIUS Act stablecoin rules in draft form, even as the 18 July deadline for finalising them approaches with the rulebook still incomplete.
The seven agencies required to complete rulemaking by 18 July are the Office of the Comptroller of the Currency (OCC), the FDIC, the Federal Reserve, the National Credit Union Administration (NCUA), the Treasury, FinCEN and OFAC. Between December 2025 and June 2026, they released proposals covering capital, reserves, liquidity, redemption, financial crime and credit union-affiliated issuers. The proposals are not yet binding, but the direction they set is consistent: higher capital and liquidity standards, tighter reserve rules, and bank-style compliance obligations.
What the GENIUS Act Stablecoin Rules Already Require
The statute’s core requirements are already fixed and will not change in the final text. Every permitted issuer must hold 1:1 reserves in eligible assets. Rehypothecation of those reserves (using them as collateral for other transactions) is banned for most purposes. Issuers must publish monthly reserve reports certified by the chief executive and chief financial officer, accompanied by a third-party attestation from a registered accounting firm.
The OCC published its proposed rule in the Federal Register on 2 March 2026, with the most comprehensive scope of any agency proposal. Mayer Brown‘s analysis of the proposal confirms it would establish a new 12 CFR Part 15 and amend four existing parts (3, 6, 8 and 19), covering licensing, reserves, prudential standards, custody, capital, reporting, supervisory fees and enforcement.
On capital, the OCC has proposed a $5 million minimum floor for new federal issuers, with additional risk-based requirements for larger or more complex firms. On reserves, eligible assets would be limited to cash, balances at Federal Reserve Banks, insured demand deposits, Treasury bills and overnight Treasury repos.
Liquidity and redemption carry their own tests. Under the OCC’s quantitative option, at least 10% of outstanding stablecoins must be redeemable on the same business day and at least 30% within five business days. Standard redemption is at par within two business days of a valid request. If requests exceed 10% of outstanding issuance in a rolling 24-hour period, issuers have up to seven calendar days to complete redemptions while notifying the regulator immediately.
The NCUA, FinCEN and the Federal Reserve’s Unfinished Role
The NCUA published its operational-standards proposed rule in the Federal Register on 18 May 2026, amending five parts of its existing regulations. In its press release announcing the rule, the agency stated that it ‘worked diligently to align the standards for NCUA-licensed PPSIs with the standards that are proposed for bank subsidiaries.’ The comment period on that proposal closes on 17 July, one day before the statutory deadline.
The FinCEN and OFAC joint proposal, published on 8 April 2026 (one secondary source cites 10 April; the primary FinCEN document and Willkie’s compliance analysis cite 8 April), covers AML programmes, suspicious activity reporting, sanctions screening and the ability to freeze tokens. The FinCEN fact sheet confirms that maintaining an effective sanctions compliance programme would be a condition of operating as a permitted issuer. FinCEN estimates the rules would initially apply to around 50 issuers. Covington and Burling notes that the AML requirements largely track the obligations already imposed on other Bank Secrecy Act-regulated institutions.
The Federal Reserve has not published a standalone proposal for the issuers it supervises, joining only the interagency customer identification proposal released in June. That leaves subsidiaries of state member banks without the agency-specific roadmap that OCC- and FDIC-supervised issuers already have.
When Compliance Actually Kicks In
18 July is a deadline for regulators, not for issuers. Under the GENIUS Act, the framework becomes effective 120 days after the primary federal regulators publish their final rules, or on 18 January 2027, whichever comes first. In practice, issuers are unlikely to face the new regime before mid-November 2026 at the earliest. Once the final AML rule is published, issuers have a further 12 months to implement the required compliance programmes.
The longest transition applies to distributors rather than issuers. From 18 July 2028, exchanges, brokers and custodians will no longer be able to offer stablecoins in the US unless issued by a permitted domestic issuer or a registered foreign issuer.
The issuer landscape is already uneven. Circle and Paxos received conditional national trust bank charters from the OCC in December 2025. Ripple has applied for a charter and holds RLUSD reserves in Treasuries and money market funds through BNY Mellon, but its application remains pending. Tether’s USDT reserves include asset classes outside the proposed eligible list, and no jurisdiction has yet received a Treasury determination that its regulatory framework is comparable to the US model.
The OCC sought comment on more than 200 open issues, so the final text could still shift materially. The 120-day clock does not start until that final text is published, making the publication date itself the most consequential variable left to watch.
