OCC Finalizes Stablecoin Rule Allowing Case-by-Case Review of Rewards Programs
The OCC finalized its stablecoin rule on October 21, dropping a proposed presumption that rewards programs violate the GENIUS Act's interest ban and opting for case-by-case review, allowing Coinbase's 3.75% USDC rewards to continue for now.
Why it matters
The OCC's case-by-case approach gives exchanges and issuers regulatory flexibility but creates uncertainty, as rewards programs like Coinbase's USDC yield lack a safe harbor and could face future enforcement. The decision contrasts with banking industry pressure for stricter interpretation of the GENIUS Act's interest ban.
Key facts
The GENIUS Act passed in July 2025 prohibits stablecoin issuers from paying interest to holders.
Reported by Unchained
Coinbase pays 3.75% annually to USDC holders who subscribe to Coinbase One.
3.75 %Reported by Unchained
Coinbase funds the rewards itself and receives a revenue share from Circle's reserve interest.
Reported by Unchained
The OCC dropped a proposed presumption that rewards payouts violate the interest ban, opting for case-by-case review.
Reported by Unchained
Banks argued rewards programs amount to interest paid another way and urged stricter OCC rules.
Reported by Unchained
The CLARITY Act failed in September with rewards programs as a major sticking point.
Reported by Unchained
Coinbase's USDC rewards can continue but have no safe harbor and remain open to challenge.
Reported by Unchained
What happened
The Office of the Comptroller of the Currency finalized its rule for nonbank stablecoin issuers on October 21, effective January 18, 2027. The regulator dropped a proposed presumption that rewards payouts to stablecoin holders violate the GENIUS Act's ban on interest payments, choosing instead to evaluate each arrangement case by case. This means Coinbase's program paying 3.75% annually to USDC holders in its Coinbase One tier can continue, though the rule provides no safe harbor and the rewards remain open to challenge. Banks had urged stricter rules, arguing such rewards amount to interest paid another way. The CLARITY Act, a broader crypto market-structure bill that also addressed rewards, failed in September.
How the story developed
- Official statement
OCC finalizes stablecoin rule
Rule effective January 18, 2027 drops proposed presumption against rewards, adopts case-by-case review
- First report
First report by Unchained
Are You Sure Your USDC Rewards Are Safe?
- Update
GENIUS Act becomes law
Stablecoin law passed in July 2025 banning interest payments to holders
- Update
CLARITY Act fails in Congress
Broader crypto market-structure bill fails in September with rewards as sticking point
- Update
Unchained reports on OCC rule and implications for Coinbase USDC rewards
Article published analyzing the rule's impact on Coinbase's 3.75% USDC rewards program
Affected entities
Original sources
| Publisher | Report | Role | Published |
|---|---|---|---|
| Unchained Crypto media | Are You Sure Your USDC Rewards Are Safe? | Original |
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