Banking and Finance Law Daily Wrap Up, FINANCIAL TECHNOLOGY—OCC seeks comment on GENIUS Act payment stablecoin application forms, (Jul 24, 2026)

By WK Editorial Staff

A new information collection seeks to cover businesses and other for-profit entities that want to become permitted payment stablecoin issuers or foreign issuers registered with the OCC.

The Office of the Comptroller of the Currency (OCC) is seeking comment on proposed application forms for entities seeking approval or registration to issue payment stablecoins under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). Comments are due by Dept. 25, 2026. After the 60-day period, the OCC will publish a second notice with a 30-day comment period.

For applicants seeking permitted issuer approval, the forms would require an overview, a detailed business plan, and information tied to the OCC’s evaluation factors which include financial condition and resources, redemption policy standards, and the competence, experience, and integrity of officers, directors, and principal shareholders. The notice identifies core filing categories that stablecoin businesses will need to assemble before filing, including reserve policy and requirements and the applicant’s risk management policy and program. Finally, the officers, directors, and principal shareholders must also submit the information specified in the Interagency Biographical and Financial Report.

In the case of a foreign issuer seeking licensing or registration, the OCC would first evaluate whether the Secretary of the Treasury has determined whether the foreign issuer is subject to a comparable payment stablecoin regulatory and supervisory regime. The OCC then would review the financial and managerial resources of the issuer’s United States operations. The agency also would consider whether the issuer will provide adequate information for compliance review, whether it presents risks to United States financial stability, including timely redemption for United States customers, and whether it presents illicit finance risks. The foreign issuer application would have to include evidence of the Treasury comparability determination and certifications designed to support OCC oversight. Those include a certification that the applicant will make available information the OCC deems necessary to determine and enforce GENIUS Act compliance, consent to United States jurisdiction for enforcement of the GENIUS Act and agency’s proposed rules that are to be codified at 12 C.F.R. Part 15, and a certification that filings and supporting materials contain no material misrepresentations or omissions.

Regarding the proposed information in general, the OCC seeks comments on whether the collection is necessary and useful and that the burden estimate is accurate. Other comments sought relate to how the information could be clearer; reducing any burden through automation or other information technology; and what capital, start-up, operating, maintenance, and service costs are expected to be incurred.

RegulatoryActivity: BankingOperations FinancialIntermediaries FinancialStability FinTech PrudentialRegulation