GENIUS Act Rule Is Final: OCC Offers No Safe Harbor for Existing Stablecoin Rewards

TLDR: The OCC’s first GENIUS Act rule takes effect on January 18, 2027, covering issuance and custody. Existing yield and rewards programs get no grandfathering or automatic safe harbor under the rule. Issuers cannot pay yield solely for holding stablecoins, but some third-party rewards may qualify. Coinbase, PayPal, and Kraken programs face uncertainty as the OCC reviews each case individually. The GENIUS Act rule is now final, according to the Office of the Comptroller of the Currency (OCC). It is the agency’s first final rule implementing the stablecoin law. The rule covers issuance, custody, and third-party partnerships.