being proposed, and discussions with organizers. 25 Stablecoin Issuers will also be required to develop a process to assess and meet their particular capital requirements, which will be evaluated by the OCC through the examination process, as discussed below. The initial minimum capital requirement will apply during a “de novo” period following the OCC’s chartering or licensing of a Stablecoin Issuer or, for state Stablecoin Issuers, following the transition to the OCC’s supervision. The de novo period will generally be three years, but may be extended or shortened by the OCC under certain circumstances. The Proposed Rules would include a $5 million floor on the minimum capital requirement during this de novo period. The Proposing Release acknowledges this floor is intended to ensure that Stablecoin Issuers have sufficient resources to support initial operations and cover losses arising during the early startup phases of new payment stablecoins. The Proposed Rules would also create an operational backstop requirement where Stablecoin Issuers would hold designated pools of highly liquid assets to maintain ongoing operations during a business disruption. This would be independent of de novo or ongoing capital requirements and would be assessed quarterly. The capital requirements would function as a loss-absorption tool, whereas the operational backstop would serve as a liquidity tool to facilitate timely redemptions in times of stress.
Redemptions
The Proposed Rules would impose redemption requirements on Stablecoin Issuers consistent with the GENIUS Act. The Act requires that a Stablecoin Issuer’s redemption policy be publicly disclosed, and the Proposed Rules would require certain information to be contained within the redemption policy. Such required information would include: the timeframe in which the Stablecoin Issuer will redeem payment stablecoins, which may not exceed two business days;
a statement that the timeframe may be extended in certain scenarios;
a statement that any discretionary limitations on timely redemptions can only be imposed by the OCC, or, for a state-regulated Stablecoin Issuer, by the OCC, Federal Reserve, or the applicable State regulator;
a statement with instructions on how a holder can redeem their payment stablecoins; and
the minimum number of stablecoins a Stablecoin Issuer will redeem. 26
Under the Proposed Rules, a Stablecoin Issuer generally must process a redemption within two business days after the date of the requested redemption. However, a Stablecoin Issuer that faces redemption requests in excess of 10% of its outstanding issuance value in a single 24-hour period would be required to provide notice to the OCC within 24 hours, and the redemption period would be automatically extended to seven calendar days following the requested redemption date. This
See OCC, Bulletin 2007-21 (June 26, 2007).
25
26 Under the Proposed Rules, an issuer must redeem a request for one or more stablecoins, but is permitted to set the minimum lower than one.
March 2026 / Page 14
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