GENIUS Act: Revised Reporting Forms and Instructions for Permitted Payment Stablecoin Issuers Subject to the Jurisdiction of the Office of the Comptroller of the Currency
AI Analysis
The OCC has revised proposed Forms PS-01 and PS-02 for OCC-supervised permitted payment stablecoin issuers and registered foreign payment stablecoin issuers, following feedback on its June 2026 proposal and the OCC’s October 21, 2026 final rule implementing the GENIUS Act. Subject to Office of Management and Budget approval, issuers would face standardized weekly reporting on stablecoin activity and reserves beginning with the January 25, 2027 report date and quarterly financial-condition reporting beginning with the March 31, 2027 report date.
Key dates
- 2026-10-21
- OCC publishes Bulletin 2026-52, revised PS-01 and PS-02 forms for public comment, and issues its GENIUS Act implementing final rule.
- 2027-01-18
- The OCC final rule implementing the GENIUS Act and the GENIUS Act take effect, according to the OCC’s related final-rule materials.
- 2027-01-25 Deadline
- First weekly PS-01 report date, subject to OMB approval of the information collection.
- 2027-03-31 Deadline
- First quarterly PS-02 report date, subject to OMB approval of the information collection.
Suggested considerations
- Compliance teams at affected issuers should review the revised PS-01 and PS-02 workbooks and instructions and identify every required data element, reporting frequency, aggregation rule, and responsible control owner.
- Firms should consider submitting comments within 30 days after publication of the information-collection notice in the Federal Register, with particular attention to data availability, calculation methodology, confidentiality, reporting burden, and transition timing.
- Issuers should map daily issuance, redemption, reserve, ownership-concentration, and trading data to PS-01 and test whether systems can produce a complete weekly submission for the January 25, 2027 report date, subject to OMB approval.
- Issuers should assess whether finance and regulatory-reporting systems can produce PS-02 information on income, assets, liabilities, off-balance-sheet activities, and capital for the March 31, 2027 report date.
- Firms should establish governance for data certification, reconciliation to general-ledger and reserve records, exception management, senior review, and retention of supporting documentation for OCC examination.
- Issuers should assess the interaction between the reporting forms and the final rule’s reserve, redemption, risk-management, audit, capital, custody, and supervisory requirements, rather than treating the forms as an isolated reporting exercise.
- Foreign issuers should confirm their OCC registration status, reporting perimeter, U.S. activities, and allocation of information-production responsibilities between U.S. operations, parent entities, and service providers.
What changed
The OCC is reopening public comment on revised weekly Form PS-01 and quarterly Form PS-02 and their instructions. PS-01 requires daily data compiled and submitted weekly for each payment stablecoin, covering issuance, reserves, ownership concentration, and trading activity. PS-02 requires quarterly reporting on the issuer’s condition and income, including balance-sheet assets and liabilities, off-balance-sheet activities, income, and capital. The revisions are intended to align the forms with the final rule in new 12 CFR part 15 and to support OCC supervision, compliance monitoring, and transparency regarding issuers’ financial condition. The collection remains subject to OMB approval; the bulletin does not itself establish a final comment deadline because that deadline runs 30 days from p
Compliance impact
The impact is high for affected issuers because the proposal converts stablecoin activity, reserve, and financial-condition data into recurring supervisory reporting obligations, with weekly operational data and quarterly financial reporting. Independent legal and industry commentary characterizes the broader OCC rule as establishing enforceable reserve, redemption, capital, risk-management, audit
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original OCC source before acting. Full disclaimer.
What the OCC said
The Office of the Comptroller of the Currency (OCC) is finalizing a new information collection that would include weekly and quarterly reporting forms that must be completed by permitted payment stablecoin issuers and foreign payment stablecoin issuers registered with the OCC under the Guiding and Establishing…
Extract from OCC . Read the full notice at the source for the authoritative text.