US regulators start writing the stablecoin rulebook the GENIUS Act ordered
Passing the GENIUS Act in 2025 was treated as the finish line for US stablecoin regulation. It was the starting line. The Fed, OCC and FinCEN are now writing the rules that actually bind issuers, with an OCC deadline in November.
Published · 2 min read
A law is a skeleton. The GENIUS Act, the US stablecoin statute, became law in 2025, but the rules that actually bind issuers are being written now, agency by agency. On September 24, the Federal Reserve moved on its own proposals to implement the Act, according to CoinDesk, the latest step in a rulemaking effort that has run all year.
For anyone tracking US stablecoin policy, that is the real story: the framework is settled, the operative detail is not.
What the rules actually cover
The Act itself requires issuers of payment stablecoins to hold 100 percent reserves in liquid assets, disclose them monthly, and hold a federal or state license. The rulemakings fill in how that works in practice. On June 18, FinCEN, the Fed, the OCC, the FDIC and the NCUA jointly proposed customer identification program requirements for what the law calls permitted payment stablecoin issuers, under the Bank Secrecy Act, and the OCC issued a parallel proposal on sanctions and anti-money-laundering compliance.
The clock: an OCC final rule by November
There is a near-term deadline. The Comptroller of the Currency, Jonathan Gould, told the Wyoming Blockchain Symposium on August 19 that the OCC would finalize its implementing rule by November, according to Forkast citing the agency’s own release. That is the date that turns proposals into binding rules for the issuers the OCC supervises.
“A law sets the framework. The rules that bind issuers are written afterward, by the agencies.”
All of this governs the coins whose backing we broke down in stablecoins explained, and it includes the unresolved question, whether stablecoins may pay yield, that helped stall the broader market-structure bill in the Senate.
Our take
The takeaway is simple: the law is done, the rules are not. The binding detail, who gets licensed, what counts as a reserve, how issuers verify customers and screen for sanctions, is being decided in these proposals, with the OCC’s November deadline the next real marker. Watch the rulemakings, not the press release. This is news, not legal advice.
Frequently asked
What is the GENIUS Act?
A US law directing regulators to write the first federal rulebook for payment stablecoins — covering reserves, disclosures and who is allowed to issue them.
What will the stablecoin rules likely require?
Full reserve backing, regular disclosure of what stands behind each token, and licensing for issuers.
Why does it matter for people who hold stablecoins?
Clear rules could make stablecoins safer and more widely usable, but may also limit which tokens are allowed to operate in the US.