In its final GENIUS Act rule, the OCC said none of the current bank and nonbank stablecoin issuers identified in its analysis qualified as small entities under the Regulatory Flexibility Act. The figures show where the agency is starting as it encourages community banks to consider issuing their own coins.
The OCC counted about 602 small entities among the 986 institutions it supervises, or about 64%. The agency’s regulatory analysis used an asset cutoff of $850 million for commercial banks and savings institutions and $47 million for trust companies. The agency grouped bank and nonbank issuers in its discussion of current issuance and provided no dollar totals by bank asset size.
In Oct. 27 remarks to the Ohio Bankers League, Comptroller of the Currency Jonathan Gould said interested community banks could explore issuing through subsidiaries and that the requirements were “meant to fit the size and risk of the issuer.”
Two requirements vary with the operation. Eligible reserves must cover the value of outstanding coins, and the operating backstop generally equals 12 months of the issuer’s expenses. The capital floor applies at any scale, and the OCC can set a higher requirement based on the issuer’s risks. Some commenters argued that the $5 million minimum would restrict entry for small applicants. The OCC retained it and extended it beyond the startup period.
The Downstream Test Is Interbank Settlement
A lender using an existing coin can start with a transfer it already makes to another bank. Its payments team can measure the time until the receiving bank has usable funds, the work required to reconcile the transfer and the number of counterparties it can reach. The institution that issues the coin is responsible for backing it and redeeming it at par. That division of work gives small lenders a way to evaluate settlement before committing capital to an issuance business.
As for the interest shown by small institutions, PYMNTS Intelligence data offers a window into where, and even when, small financial institutions are eyeing a more comprehensive set of stablecoin initiatives. “Credit Unions Build for Digital Money’s Next Chapter,” based on responses from 500 credit union executives in the United States, found in September a 25-percentage-point gap between readiness and active engagement among institutions classified as quick followers. The survey measured preparedness to support stablecoins and whether institutions were already engaged. It gave no count of prospective issuers. Across the survey, 52% of executives cited cybersecurity and fraud risk as a barrier to engaging with cryptocurrency more broadly, and 44% cited member demand.
The North Dakota interbank rollout illustrates the arrangement. Banks and credit unions can participate voluntarily, with Versabank issuing Roughrider Coin and Fiserv supplying the infrastructure. The Bank of North Dakota reported faster settlement among early users. Its initial account gave no transaction volumes or count of active lenders. These figures would show whether institutions are using the service for recurring payments and how much business they are putting through it.
Separately, OnePay lets some U.S. customers send USDC and receive dollars in their checking accounts, according to a Friday (Oct. 30) company blog post. In terms of the competitive jockeying for customers’ accounts, a traditional bank would conceivably seek to offer the same service so customers who receive USDC can move the money straight into the checking account they already use.
The OCC’s final rule takes effect Jan. 18, 2027. Its filing guidance said the agency will announce when it begins accepting applications after federal approval of the forms. Community bank filings would identify institutions willing to take on issuance. For small lenders testing the technology downstream, the measure is how many of their routine payments they actually settle that way.
