The American Bankers Association (ABA) is objecting to the Office of the Comptroller of the Currency's finalized rules under the GENIUS Act, taking issue with how the rule treats yield arrangements for payment stablecoins.
What the OCC finalized
The OCC issued its final rule on October 21, 2026. It sets out how payment stablecoins will be issued and supervised in the US and takes effect on January 18, 2027.
The rule implements the GENIUS Act, which became law on July 18, 2025. The statute sets standards for reserves, redemption, risk management and auditing. It tells issuers what must back their tokens, how holders get their money out, and who checks the books.
One notable gap: the law does not include explicit anti-money laundering provisions. Those are being handled separately by the Treasury, so the OCC's rule is only one piece of the eventual framework.
This is the first major agency rulemaking under the 2025 law. The rule covers national banks, federal savings associations and certain state-qualified payment stablecoin issuers, along with some nonbank issuers that fall under OCC jurisdiction.
The yield loophole, explained
The ABA's objection centers on so-called indirect yield arrangements. Under the GENIUS framework, issuers themselves are not supposed to pay yield on payment stablecoins. The question is what happens when a third party, such as an exchange or other crypto platform, hands out rewards to stablecoin holders instead.
The OCC's proposed version of the rule had included a rebuttable presumption against certain of these indirect payments. The final rule drops that presumption. Instead, the OCC will evaluate these arrangements case by case.
The ABA argues the change opens a significant loophole that undercuts what the GENIUS Act was meant to do. In the association's reading, Congress wanted a clear line between stablecoins and traditional bank deposits, partly to protect the money banks lend out in local communities.
ABA President Rob Nichols said the final rule risks undermining Congress's intention to protect local lending. He also suggested it may end up preserving the status quo for crypto platforms, which would not line up with what lawmakers were aiming for.
Community banking associations have voiced similar worries. They have raised concerns about risks to local lending capacity and to broader financial stability.
What this means for issuers, platforms and banks
For banks, the immediate options are limited. The rule is final, so the ABA's criticism functions mostly as a public marker. It signals that the industry intends to keep pressing on yield, whether through comments on future guidance, engagement with other agencies or appeals to lawmakers.
There are several things worth watching from here. First, how the OCC applies its case-by-case standard to the first real yield arrangements it reviews. Second, what the Treasury produces on anti-money laundering, which remains a separate track under the law. Third, whether other regulators implementing the GENIUS Act take a stricter or looser view on indirect yield, creating gaps between charters.
