OCC leaves stablecoin reward programs to case-by-case review

The Office of the Comptroller of the Currency finalized a stablecoin rule that bars issuers from paying interest or yield solely because a customer holds, uses or keeps a payment stablecoin, while leaving some exchange reward programs open to case-by-case review. The rule implements the GENIUS Act, signed into law in 2025. The Associated Press reported that exchanges such as Coinbase and Robinhood can pass earnings to customers as rewards under the OCC’s approach. The rule takes effect Jan. 18, 2027.

How does the rule separate issuers from exchanges?

A stablecoin issuer creates the token and promises to redeem it for a fixed amount of money. To back that promise, issuers hold reserve assets such as bank deposits and U.S. Treasury securities, which can earn interest. The GENIUS Act prohibits permitted issuers from paying holders interest or yield solely in connection with holding, using or retaining their payment stablecoins.

An exchange is a separate business that trades or holds tokens for customers. It may offer customers rewards connected to stablecoins, but the rule does not create a blanket exemption for those programs. The OCC says an arrangement must be assessed on its facts, including whether a payment is interest or yield and whether it is made solely because someone holds, uses or retains a stablecoin.

What did the OCC change in the final rule?

The OCC removed a proposed rebuttable presumption that would have treated certain indirect payments as prohibited unless an issuer could show otherwise. Instead, the agency will apply the statute to each arrangement’s facts and circumstances. The final rule published in the Federal Register says the OCC retains authority to address evasion of the law, including cases where a third party may be acting on an issuer’s behalf.

The OCC also declined to define “interest” or “yield” and did not establish a general safe harbor for rewards programs. A payment called a reward could still count as interest or yield based on its substance. The agency says transaction-based payments may fall outside the ban if they are not yield or are not paid solely because of stablecoin holding, use or retention; that determination also depends on the specific arrangement.

What remains uncertain for customers?

The final rule leaves platforms without a universal checklist for designing rewards. A program’s funding, terms and relationship to the issuer may matter when regulators assess it. The OCC received about 328 comments on its proposal and said it will evaluate particular arrangements as they arise.

For customers, the distinction is between a stablecoin issuer paying yield for holding its token, which the law prohibits, and a platform reward that may have a different structure. The latter is not automatically allowed. Stablecoins also do not carry the same federal deposit insurance as bank accounts, so an interest-like reward does not make a token a bank deposit.

Sources

• Associated Press reported — apnews.com
• final rule published in the Federal Register — govinfo.gov