The GENIUS Act rules are final but can stablecoin issuers get approved in time?

The OCC has fixed January 18 as the start of its stablecoin rules, but it has not opened the application window. Its new waiver guidance explains how an existing issuer could keep minting while a decision is pending, and where that protection stops. Summary The OCC’s final GENIUS Act rule takes effect January 18, 2027. Existing issuers can request a waiver lasting no more than 12 months from January 18. A waiver requires a substantially complete application pending with the OCC. Weekly reporting is proposed to begin with the January 25, 2027, report date. The OCC has not announced when it will begin accepting applications or waiver requests. The Office of the Comptroller of the Currency has finalized its GENIUS Act regulations with less than three months left before the January 18, 2027, effective date. The OCC’s final rule bulletin sets the date and identifies the issuers it will supervise. Its accompanying waiver guidance acknowledges a problem that the rule itself cannot make disappear: existing businesses need permission to continue issuing payment stablecoins once the law starts, and the agency has yet to begin taking their applications. For an issuer, the consequential questi...