Stablecoin Issuers Could Break the Rules Without an OCC Waiver

TLDR Existing US stablecoin issuers awaiting OCC approval need a granted waiver to keep issuing after Jan. 18, 2027. A pending application alone will not authorize continued issuance once the GENIUS Act takes effect. Waivers are capped at 12 months and may be shorter, depending on each applicant’s needs. The OCC generally expects to grant waivers to issuers already operating in the US with substantially complete applications. As of Oct. 21, the OCC had not opened intake for applications or waivers, pending final OMB approval.