The Office of the Comptroller of the Currency (OCC) has released a 376-page proposal outlining how it plans to implement the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, in a move that could help settle the ongoing debate over stablecoin yield.
The proposal, published Wednesday, is open for public comment for 60 days. It sets out detailed requirements for permitted payment stablecoin issuers operating under the OCC’s supervision.
Under the draft rules, supervised entities would be prohibited from offering any form of interest or yield — whether in cash, tokens or other incentives — provided “solely in connection with the holding, use, or retention” of a payment stablecoin. The restriction aligns with Section 4(a)(11) of the GENIUS Act.
Thania Charmani, a partner at global law firm Winston & Strawn, wrote on X that the OCC appears to be attempting to “resolve the debate on stablecoin yield through rulemaking,” potentially allowing the Digital Asset Market Clarity Act of 2025 (CLARITY) to move forward without addressing that issue directly.
How the OCC proposal implements GENIUS on yield
The GENIUS Act, enacted in July 2025, established a federal regulatory framework for payment stablecoins. It limits issuance in the United States to licensed “permitted issuers,” including bank subsidiaries, newly chartered federal stablecoin entities and certain large state-regulated firms.
The Office of the Comptroller of the Currency’s draft rule converts the statutory framework of the GENIUS Act into concrete operational limits, including strict guardrails on how regulated issuers can design the economics of their stablecoins.
Beyond restating the law’s ban on yield, the proposal introduces a rebuttable presumption of noncompliance. An issuer would be presumed to violate the prohibition if it pays yield to an affiliate or “related third party” that then passes yield on to holders of the issuer’s payment stablecoin.
While issuers may attempt to rebut that presumption by submitting written evidence to the OCC, the agency emphasizes the “close nexus” between issuer payments and end-holder rewards. It characterizes such arrangements as “highly likely” efforts to circumvent the statute.
The proposal also outlines two explicit carve-outs. It clarifies that merchants may independently offer discounts for customers who use payment stablecoins, and that issuers may share stablecoin-related profits with a non-affiliate partner in a white-label structure.
What the proposal means for CLARITY and Coinbase
If adopted in its current form, the OCC’s rule would significantly influence the parallel debate surrounding the Digital Asset Market Clarity Act of 2025 (CLARITY), particularly on the issue of stablecoin rewards.
Draft versions of CLARITY have wrestled with whether digital asset service providers should be permitted to offer yield or rewards on payment stablecoin balances — a contentious issue that has drawn pushback from industry players, including Coinbase.
By prohibiting yield at the issuer level under GENIUS implementation, the banking regulatory framework effectively sets a no-yield baseline for GENIUS-compliant, OCC-supervised payment stablecoins.
For Coinbase and similar firms that have argued they should be able to provide yield on stablecoin balances within a fully regulated US regime, the regulatory signal is clear: stablecoin yield and GENIUS-compliant, OCC-supervised payment stablecoins are being placed on opposite sides of the compliance divide.
