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The Office of the Comptroller of the Currency (OCC) has released draft regulations clarifying how the GENIUS Act will apply to stablecoins. The document is purely practical: it does not repeal the prohibitions of the law, but explains how the regulator will apply them to specific schemes, issuers and intermediaries. One of the most pressing issues is the reward for storing tokens. GENIUS does not allow the issuer to pay the holder interest or similar income simply for the fact that the stablecoin is in the account. However, market participants began to offer such payments through third-party platforms, partner services and affiliated structures. Initially, the OCC was ready to consider such schemes an automatic violation with the risk of losing the license. In the published draft, the approach is different: the regulator will analyze each program separately, and the existing loyalty programs launched before GENIUS came into force will be reviewed retrospectively and decide whether they comply with the law.

A separate section is the licensing terms. According to GENIUS, from January 18, 2027, the issuance of payment stablecoins in the United States will require a license, and working without it will face criminal liability. Companies that have applied before this date will be able to request a temporary waiver for up to a year. The OCC expects to grant such exceptions to issuers that already operate in the United States and have stablecoins on the market. The regulator will announce the start date for accepting applications separately.

For issuers, there is more freedom in how to manage reserves. Those who exclusively issue tokens should keep reserves only for their own issued stablecoins, and on the principle of "one token — one unit of fiat." It is specified separately who is generally considered a client.: This is someone who bought tokens directly from the issuer or came to him for a ransom. If a person has purchased stablecoins on an exchange or somewhere else, he does not become a client of the issuer until he applies for a buyout. This means that the issuer is not responsible for such tokens when the wallet is blocked, and is not obliged to verify the holder according to the "know your customer" procedure.

There is one more clarification about wrapped stablecoins. According to OCC, they do not belong to payment stablecoins, therefore they do not fall under GENIUS. They do not need to confirm a 1:1 reservation in fiat currency, and a direct ban on the payment of income by the issuer does not apply to them either. For projects that use wrapped tokens in decentralized services and want to maintain a different economic model, this is an essential point.