OCC Finalizes GENIUS Act Stablecoin Rules, Drops Third-Party Reward Presumption

The OCC's first-mover status matters less than the signal it sends: federal stablecoin issuance now has a concrete procedural path, and other regulators face pressure to match its timeline. The removal of the third-party reward presumption is the substantive tell — it preserves room for distribution partnerships and loyalty-style incentives while keeping the direct-interest ban intact, drawing a line between yield and marketing. That distinction will shape how issuers structure arrangements with exchanges and fintechs. The long lead time to January 2027 leaves ample room for litigation, further rulemaking, or congressional pushback, and whether other agencies align with the OCC's approach is the open question.