The Office of the Comptroller of the Currency (OCC) closes its GENIUS Act comment window on May 1. The four-day countdown ends 18 months of regulatory uncertainty for U.S. banks weighing payment stablecoin issuance.
The deadline marks a turning point for corporate treasurers who have weighed stablecoins as a primary payment rail. Many lacked formal federal guidance from the agency that supervises national banks.
Two-Tier Framework Puts the Compliance Burden on Issuers
The OCC opened the 60-day window on February 25 with a 376-page proposed rule.
“After that, the regulatory uncertainty that’s been keeping corporate treasury teams from making stablecoin their primary payment rail has an official federal answer —> from the same agency that supervises national banks,” stated investor Abhinav Kumar.
That rule translates the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act into operational requirements. It spans reserve standards, custody rules, capital thresholds, and supervisory authority.
A two-tier licensing structure anchors the proposal. Issuers with more than $10 billion in outstanding stablecoins fall under federal licensing.
Smaller firms can operate under state regimes certified by the Treasury, Federal Reserve, and FDIC.
The compliance burden lands on issuers, not on payment infrastructure operators or merchants.
That distinction matters for corporate adoption, where the missing piece has been formal legal cover rather than merchant skepticism.
Corporate Treasuries Eye the Switch to Stablecoin Rails
An EY-Parthenon survey found that 13% of financial institutions and corporates globally already use stablecoins. Another 54% of non-users plan to adopt them within six to 12 months.
Kumar argues the gap between interest and execution comes down to legal cover. He says the OCC framework will turn the opinion letter from general counsel into a form document.
“The companies ready to receive that demand will have a structural advantage that’s very hard to replicate 18 months later,” he added.
The American Bankers Association has asked regulators for an additional 60 days to review the proposal.
That request signals the final rule may take longer to publish even after May 1 closes the comment period.
Fed leadership questions are also moving in parallel. Senator Thom Tillis said this week he will support Kevin Warsh’s Federal Reserve confirmation after the Justice Department closed its Powell investigation.
The Fed helps certify state stablecoin regimes alongside Treasury and the FDIC, tying central bank leadership to how the framework rolls out under federal stablecoin policy.
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