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OCC Stablecoin Regulatory Final Rule Issued: Issuers Barred From Direct Interest Payments

The final rule accompanying the U.S. GENIUS Act has been issued, establishing the OCC's stablecoin regulatory framework with explicit requirements for key areas including stablecoin issuance, reserves, redemption, and custody, while further clarifying the boundaries of yield mechanisms. The core constraint of the rule is that stablecoin issuers may not pay interest directly to holders, while rewards offered by exchanges retain some room. This yield mechanism arrangement directly determines whether stablecoin products can offer returns to holders and in what manner, and therefore directly affects product design and market promotion. It has become a core change watched by the market and is also seen as an important regulatory development shaping the stablecoin industry landscape.

In the issuance segment, the final rule places issuance requirements at the core. Issuers need to maintain a clear boundary between issuance and yield mechanisms. With the above yield boundary clarified, stablecoin products cannot continue to use direct interest payments to holders for yield distribution; exchange-level reward arrangements have not been completely closed off. This means regulation does not simply ban all yield arrangements, but distinguishes between direct interest payments by issuers and exchange rewards. For issuers, this boundary constrains designs involving direct interest payments but does not entirely close the space for exchanges to conduct reward activities. How the relevant boundaries will be implemented still needs support from subsequent formal documents and authoritative interpretations.

Reserves and redemption are two segments included in the final rule at the same time, not merely principle-based reminders. Reserve requirements focus on the backing arrangements behind stablecoins, while redemption requirements focus on the path for holders to redeem according to the rules. The two are directly related to the redemption foundation of stablecoins and the exit mechanism for holders. By placing reserves and redemption within a unified framework, the final rule shows that regulatory attention is not limited to compliance at the point of issuance, but also extends to the underlying arrangements and exit arrangements during the life of the stablecoin. For issuers, reserves and redemption are no longer separate business details but core segments that need to be incorporated into the overall compliance framework. Specific implementation details for reserves and redemption still await further authoritative information.

Custody is another segment explicitly covered by the final rule. The rule sets requirements for custody, extending the scope of stablecoin regulation from issuance, reserves, and redemption to custody services. After the final rule brings custody into a unified set of requirements, relevant service segments need to operate within the boundaries established by the accompanying rules rather than remaining outside the regulatory framework. Taken together with the four requirements of issuance, reserves, redemption, and custody, the OCC's stablecoin regulatory final rule covers key stablecoin segments and is no longer limited to a single business point. Implementation details for the custody segment still need to be clarified.

From an industry impact perspective, after the final rule is issued, issuers need to comply with the rule arrangements in areas such as reserves, redemption, custody, and yield mechanisms. The stablecoin industry's focus will shift from whether rules will be introduced to how the rules will be applied. Because the above yield boundary has been clarified, stablecoin products need to avoid direct interest payments to holders in yield design, and related reward activities also need to be conducted within regulatory boundaries. For stablecoin holders and broader market participants, the issuance of the rule provides a clear basis for observing the stablecoin compliance framework. Follow-up attention should be paid to the specific application of the final rule in issuance, reserves, redemption, and custody, as well as how issuers and exchanges understand the above yield boundary in actual business. Attention should also be paid to the adaptation process of issuers and exchanges to the final rule framework and to changes in the stablecoin industry landscape after the GENIUS Act accompanying rules are implemented. The above points of attention are all based on content already clarified by the final rule, and subsequent developments should still be subject to formal information and actual implementation.

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