The Office of the Comptroller of the Currency has proposed implementing regulations under the GENIUS Act for issuers of payment stablecoins, the law firm Pillsbury Winthrop Shaw Pittman said in a regulatory alert.

The proposal moves the 2025 stablecoin statute from enactment into rulemaking. It puts the OCC — the Treasury bureau that charters and supervises U.S. national banks and federal savings associations — at the center of compliance oversight for permitted stablecoin issuers.

Pillsbury's alert characterizes the draft as the first major implementing release under the GENIUS framework and confirms a public comment window is now open.

What does the proposal cover?

The OCC's draft translates the statute's authorization regime into operational standards. The bureau will define the conditions under which a firm can become a "permitted payment stablecoin issuer" — the statutory term for entities eligible to issue regulated stablecoins under federal supervision — and the prudential rules those issuers must satisfy once approved.

The text is expected to address several prudential areas:

• Capital and liquidity requirements
• Reserve asset composition and segregation
• Redemption timelines and examination frequency
• Anti-money-laundering and sanctions compliance certification
• Bankruptcy-remoteness structures for issuer-vehicle separation

The Pillsbury alert does not enumerate each provision but confirms the OCC has circulated draft regulatory text.

Why does the OCC lead this rulemaking?

Under the GENIUS Act, the OCC receives primary examination authority over permitted stablecoin issuers, including both bank subsidiaries and approved non-bank entities. That designation makes the bureau's draft rule the operative federal pathway for any issuer seeking national preemption.

National bank subsidiaries that wish to issue payment stablecoins must satisfy the OCC's framework. Non-bank issuers — including affiliates of payment processors and digital-asset-native firms — must apply for permitted status through the OCC process.

State-chartered trust companies and money transmitters remain under their primary state regulators. The OCC's standards, however, will shape the federal baseline any state-licensed issuer must match to access federally chartered distribution channels and national-bank custody relationships.

What changes for industry?

The biggest operational consequences fall on issuers that have waited for a federal pathway. Companies built around state money-transmitter regimes, including several New York Department of Financial Services BitLicense holders, must weigh whether to seek OCC permitted status or remain under existing state licensing.

The certification process established by the OCC will determine reserve-attestation frequency, redemption guarantees, and how issuers handle insolvency events.

Banks gain explicit authority to issue payment stablecoins through subsidiaries. Custodians and reserve managers face new requirements around asset segregation and audit transparency under the proposal.

What's the timeline?

The proposal opens a formal comment window. Trade associations, issuers, and bank lobby groups are expected to file technical objections during that period.

The OCC has signaled that additional guidance on examination procedures and reserve-attestation standards will follow the comment period, before any issuer receives a permitted-status determination.

Pillsbury's alert flagged that the comment process will determine the final supervisory standard governing the U.S. market. For banks and prospective non-bank issuers, the proposal now stands as the operative text defining the federal pathway for payment stablecoins until the bureau issues a final rule.