OCC Stablecoin Rules Could Disrupt Circle-Coinbase Yield Programs and U.S. Crypto Policy

The U.S. crypto industry is closely analyzing a sweeping 376-page proposal from the Office of the Comptroller of the Currency (OCC) that could significantly reshape stablecoin regulation and put pressure on major partnerships like Circle and Coinbase. The proposed rules, issued under the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, raise fresh concerns about the legality of stablecoin yield and rewards programs in the United States.

During recent Senate testimony, OCC Chief Jonathan Gould addressed broader crypto oversight issues, but industry leaders are focused on language in the proposal that questions whether stablecoin issuers can indirectly facilitate yield payments through third-party platforms. The OCC suggested that close financial relationships between issuers and exchanges could make it “highly likely” that yield or interest payments are being routed through intermediaries to bypass the GENIUS Act’s prohibition on issuer-paid rewards. While firms may rebut this presumption with sufficient evidence, the proposal introduces regulatory uncertainty for crypto exchanges offering stablecoin rewards.

Many in the digital asset sector have long argued that the GENIUS Act bans yield only at the issuer level, allowing third-party platforms like Coinbase to operate independent rewards programs. However, the OCC’s interpretation signals that certain third-party arrangements could be viewed as attempts to evade federal law. Legal analysts say the language leaves room for debate, but banks have seized on the issue, arguing that stablecoin yield products threaten traditional deposit models.

The proposal arrives as lawmakers negotiate the broader Digital Asset Market Clarity Act, where stablecoin rewards remain a key sticking point. If finalized, the OCC rule could influence those talks and potentially limit a significant revenue stream for crypto exchanges. For now, the proposal enters a public comment period, signaling months of continued debate over stablecoin regulation, crypto yield products, and the future of U.S. digital asset markets.