OCC leaves stablecoin rewards open to case-by-case review

The Office of the Comptroller of the Currency (OCC) finalized a rule on Oct. 21 that leaves crypto exchanges able to offer rewards tied to stablecoins, subject to case-by-case review. That matters because the GENIUS Act bars stablecoin issuers from paying interest just for holding their coins. CoinDesk’s report on the OCC rule says the agency did not declare existing exchange reward programs automatically compliant.

What does the rule say about exchange rewards?

The rule leaves the OCC to assess each arrangement on its facts. The agency said it would apply the law to “the facts and circumstances of any particular arrangement,” CoinDesk reported. It also removed proposed “rebuttable presumptions” that would have treated certain activities as violations unless firms proved otherwise.

The law’s ban covers payments made solely because a person holds, uses or keeps a payment stablecoin. A stablecoin is a crypto token designed to hold a steady value, often against the U.S. dollar. The OCC indicated that a reward made at least partly for another reason could fall outside that ban, according to CoinDesk.

Can exchanges keep their current programs?

Existing programs get no automatic pass. The OCC said their existence before the GENIUS Act took effect does not prove Congress approved them, CoinDesk reported. That means exchanges will have to see how the agency applies the rule to their specific programs.

In practice, the distinction is between an issuer paying someone simply for holding its stablecoin and a separate platform offering a reward tied to other activity. The final rule does not list which rewards qualify, so the boundary remains unclear. The OCC has not given examples of programs that would pass or fail.

When do the new rules take effect?

The rule and the GENIUS Act take effect on Jan. 18, 2027, the OCC said in its announcement of the final rule. The rule sets requirements for payment stablecoin issuers under the agency’s oversight and for some custody activities by OCC-supervised firms.

The decision leaves exchanges room to offer rewards, while making clear that the OCC will review how each program works. Crypto firms therefore face a test of their specific reward designs, rather than blanket approval for programs already in place.

Sources and documents

• CoinDesk’s report on the OCC rule — coindesk.com
• announcement of the final rule — occ.treas.gov