OCC drops proposed affiliate rewards presumption, but stablecoin yield ban stays
Summary
The OCC’s final GENIUS Act rule, effective Jan. 18, 2027, removes a proposed presumption that certain affiliate-routed stablecoin rewards violate the law. It retains the ban on issuers paying holders yield solely for holding, using or retaining payment stablecoins, and says arrangements will be assessed case by case. The OCC rejected a small-payment exemption and said issuers cannot evade the ban by using agents. Older rewards programs face the same scrutiny as newer ones; the agency will monitor compliance and may take enforcement action. It has not provided a list of permitted structures and may issue further guidance after gaining experience.
