OCC to Review Legality of Stablecoin Reward Programs Case by Case

The Office of the Comptroller of the Currency will assess the legality of stablecoin reward programs on a case-by-case basis.

CoinDesk reported on October 21 that the OCC released the final implementing rule for the GENIUS Act, the U.S. stablecoin law, that day. The rule will take effect on January 18, 2027.

The main issue is stablecoin rewards. The GENIUS Act prohibits issuers from paying customers interest or other returns solely for holding, using or maintaining payment stablecoins.

The OCC said it will apply the law based on the facts and specific circumstances of each reward program. Some rewards could be allowed if part of the payment is made for reasons other than those explicitly barred under the GENIUS Act. The agency did not provide specific examples of which reward structures would be permitted or prohibited.

The OCC also ruled out automatically treating existing reward programs as lawful. It said it would not presume that stablecoin reward programs in operation before the GENIUS Act was enacted comply with the law.

A provision in the draft rule that would have presumed some reward practices to be violations was removed from the final version. That means the OCC will review each program's operating model and payout structure individually rather than make blanket judgments on certain reward types.