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

The Office of the Comptroller of the Currency finalized rules on Oct. 21 that leave crypto exchanges able to offer stablecoin rewards, while keeping the GENIUS Act’s ban on issuers paying holders interest directly. The OCC’s final rule takes effect Jan. 18, 2027. It does not give existing reward programs blanket approval: as CoinDesk reported on the rule’s treatment of rewards, the agency will assess arrangements based on their particular facts.

Who can pay rewards under the new rule?

Stablecoin issuers such as Circle remain barred from paying holders interest or yield solely for holding, using or retaining their coins. Exchanges that custody or trade those coins, including Coinbase and Robinhood, may still pass earnings to customers as rewards, according to the Associated Press’s report on the OCC decision.

The distinction follows the GENIUS Act, signed into law on July 18, 2025. It regulates payment stablecoin issuers and prohibits them from paying holders interest or yield simply in connection with holding, using or retaining a coin. Stablecoins are designed to maintain a steady value, typically against the U.S. dollar, and their reserves can include bank deposits and U.S. Treasuries that earn interest.

That structure leaves a potential return available through an intermediary, even as the direct issuer route is closed. But the final rule does not declare every exchange program permissible. The OCC said it will apply the statutory language to each arrangement’s facts and circumstances; it also declined to presume that rewards programs already in place comply just because they predate the law.

How much room does the rule leave exchanges?

The key word is “solely.” CoinDesk reported that the OCC indicated a reward offered at least partly for other reasons could fall outside the ban, but it did not give examples or a safe harbor for existing programs. Exchanges therefore retain a possible path to rewards, while the boundary depends on how each program works and how the OCC evaluates it.

That leaves the earlier practical pattern largely intact, but changes the certainty around it. Before the final rule, the law’s restriction on issuers was clear while the treatment of exchange programs remained contested. Now there is an explicit case-by-case approach, not a general regulatory sign-off. The rule also removes proposed “rebuttable presumptions” about activities that would violate the law, according to CoinDesk.

For customers, rewards can make stablecoins more competitive with savings products. AP reported Coinbase yields of up to 3.5% on USDC balances and an average traditional savings account yield of 0.38%, citing the latest Federal Deposit Insurance Corp. figures. Those returns are not equivalent products: crypto holdings do not have the same FDIC deposit insurance as covered bank deposits.

What happens when the rule takes effect?

The OCC’s rule covers stablecoin issuance and related activities under its jurisdiction, including reserve assets, redemptions, risk management, custody and supervision. It is one part of a broader federal implementation of the GENIUS Act; the OCC said rules for Bank Secrecy Act, anti-money-laundering and sanctions requirements will come separately in coordination with the Treasury Department.

The competing stakes remain: rewards could give exchanges a stronger reason for customers to hold stablecoins, while banks and consumer advocates warn that higher yields could pull funds from deposits and that crypto rewards lack deposit insurance. The signals to watch are how the OCC applies its case-by-case test to live programs, whether other agencies’ rules alter the framework, and whether Congress changes the GENIUS Act before Jan. 18, 2027.

Sources and documents

• OCC’s final rule — occ.gov
• CoinDesk reported on the rule’s treatment of rewards — coindesk.com