Supporting Statement A

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Office of the Comptroller of the Currency
Supporting Statement
Reporting, Recordkeeping, and Disclosure Requirements Associated with Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency
OMB Control No. 1557-NEW


    A. Justification

1. Circumstances that make the collection necessary:

This supporting statement is being filed in connection with a final rule that issues regulations to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (12 U.S.C. 5901 et seq.) (GENIUS Act or the Act) regarding the issuance of payment stablecoins and certain related activities by entities subject to the OCC’s jurisdiction.  The GENIUS Act was enacted on July 18, 2025.  The Act establishes a regulatory framework for payment stablecoin activities.

The Act generally prohibits any person other than a permitted payment stablecoin issuer from issuing a payment stablecoin in the United States.1  It further prohibits digital asset service providers2 from offering or selling a payment stablecoin to a person in the United States unless the issuer is a permitted payment stablecoin issuer or the issuer is a foreign payment stablecoin issuer that meets certain requirements.3  The Act sets forth various regulatory and licensing requirements for permitted payment stablecoin issuers and foreign payment stablecoin issuers.

2. Use of the information:

In many instances, the Act states that the specific requirements applicable to the entities
(e.g., those related to capital, liquidity operational risk management), shall be set forth by regulations issued by the relevant primary Federal payment stablecoin regulator, in coordination with other relevant agencies, as appropriate.4  Twelve CFR part 15 sets forth OCC regulations implementing the GENIUS Act.  The information collection requirements in the rule are as follows:
	
Reporting Requirements
	Section 15.10(c) sets forth prohibitions that apply to permitted payment stablecoin issuers, including a prohibition on paying interest or yield to payment stablecoin holders solely in connection with the holding, use, or retention of a payment stablecoin and a general prohibition against pledging, rehypothecating, or reusing reserve assets.  Section 15.10(c)(5)(iii)(B) permits creating liquidity to meet reasonable expectations of requests to redeem payment stablecoins, such that reserves in the form of Treasury bills with a maturity of 93 days or less may be sold as purchased securities in repurchase agreements, after receiving the prior approval from the OCC, notwithstanding a general prohibition against pledging, rehypothecating, or reusing reserve assets.

Section 15.11(a)(2) requires permitted payment stablecoin issuers to demonstrate the operational capability to access and monetize the identifiable reserve assets to meet redemptions, in both normal and adverse economic, liquidity, market, and interest rate conditions, commensurate with the permitted payment stablecoin issuer’s risk profile and business model, taking into account, among other relevant factors, market access, financing channels, haircut assumptions, and operational readiness.

Section 15.11(e) sets forth specific instructions for composition reports, including their preparation requirements.  Under § 15.11(e)(2) the composition report is required to use a format like the template provided in Table 1 of § 15.11(e) and contain the total number of outstanding payment stablecoins issued by the issuer and the amount and composition of the reserves described in § 15.11(a), including the average tenor and geographic location of custody of each category of reserve instruments. 

Section 15.11(g)(1) requires a permitted payment stablecoin issuer to notify the OCC, through its OCC supervisory office, on any day in which its reserve asset amount has fallen below the minimum reserve asset amount required by § 15.11(a).  Under § 15.11(g)(4)(i), if the OCC determines that a permitted payment stablecoin issuer has not demonstrated that it meets the requirements of § 15.11(a), (b), (c), or (d), the OCC may require the issuer to submit a plan describing how the permitted payment stablecoin issuer will attain compliance and the timeline for the plan.

Section 15.12(d)(1) requires a permitted payment stablecoin issuer to provide notice to the OCC within 24 hours if it receives redemption requests in excess of 10 percent of the outstanding issuance value of any brand of payment stablecoin issued by the permitted payment stablecoin issuer in a single 24-hour period.  Under § 15.12(d)(2) a permitted payment stablecoin issuer that experiences redemption requests in excess of 10 percent of the outstanding issuance value of any brand of payment stablecoin issued by the permitted payment stablecoin issuer in a single 24-hour period may request that the OCC extend the timeframe for timely redemption.

Section 15.13(a)(3)(i) requires a permitted payment stablecoin issuer to manage interest rate risk in a manner that is appropriate to the size and complexity of the permitted payment stablecoin issuer and the complexity of its assets and liabilities.  Section 15.13(a)(3)(ii) requires a permitted payment stablecoin issuer to provide for periodic reporting to management and the board of directors regarding interest rate risk with information sufficient for management and the board of directors to assess, to an extent commensurate with their duties, the level of risk.

Section 15.13(a)(9) provides monetization and stress testing requirements.  Under section 15.13(a)(9)(i) a permitted payment stablecoin issuer is required to conduct analyses that consider a range of redemption scenarios to ensure that the reserve asset portfolio, taken as a whole, is capable of supporting timely redemption under both normal and stressed conditions.  Section 15.13(a)(9)(ii) further requires a permitted payment stablecoin issuer maintain and demonstrate to the OCC the ability to reliably access and monetize reserve assets necessary to meet redemption requests in normal and stressed conditions, taking into account: market access; financing channels; haircut assumptions; and operational readiness.  Finally, § 15.13(a)(9)(iii) requires permitted payment stablecoin issuers to engage in regular stress testing of the reserve asset portfolio in order to determine whether the portfolio of reserve assets will continue to equal or exceed outstanding issuance value in stressed conditions, including in significant positive interest rate scenarios.

Section 15.13(a)(10) covers foreign exchange risk.  Section 15.13(a)(10)(iii) requires, before engaging in foreign exchange risk management, that the permitted payment stablecoin issuer provide prior notice to the permitted payment stablecoin issuer’s supervisory office and receive the OCC’s approval.

Section 15.13(b)(7) sets forth notification of unauthorized access requirements that apply to permitted payment stablecoin issuers.  Section 15.13(b)(7)(i)(A) requires, when a permitted payment stablecoin issuer becomes aware of an incident of unauthorized access to sensitive customer information, including a customer’s private key, the permitted payment stablecoin issuer must conduct a reasonable investigation.  Under § 15.13(b)(7)(i)(B) if the permitted payment stablecoin issuer determines that misuse of its information about a customer has occurred or is reasonably possible to occur, notification to the affected or possibly affected customer and the OCC is required as soon as possible.  Customer notice must be delayed if an appropriate law enforcement agency determines that notification will interfere with a criminal investigation and the law enforcement agency provides the permitted payment stablecoin issuer with a written request for the delay.  Section 15.13(b)(7)(i)(C) requires the permitted payment stablecoin issuer to notify its customers of the misuse or possible misuse of customer information as soon as the law enforcement agency notifies the permitted payment stablecoin issuer that notification will no longer interfere with the investigation.  Under § 15.13(b)(7)(ii), if a permitted payment stablecoin issuer determines that the files of a group of customers have been accessed improperly but is unable to identify which specific customers’ information has been accessed and if the circumstances of the unauthorized access lead the permitted payment stablecoin issuer to determine that misuse of the information is reasonably possible, it must notify all customers in the group.

Section 15.14(h) requires all permitted payment stablecoin issuers to submit to the OCC, on a weekly basis, in the manner and form specified by the OCC, a confidential report containing the information requested in the form available at www.occ.gov.

Section 15.14(i) covers the quarterly reports of financial condition and its required contents.  Under § 15.14(i)(1), all permitted payment stablecoin issuers subject to OCC supervision are required to submit to the OCC a quarterly report on the financial condition of the permitted payment stablecoin issuer, including, but not limited to, income statement, expenses, balance sheet, reserves, changes in equity, investments, capital, outstanding issuance value, and assets under custody, in a standardized format as prescribed by the OCC and within 30 days of the end of the prior quarter.  The forms and instructions are available at www.occ.gov.  Under § 15.14(i)(2), each report of financial condition is required to contain a declaration by the permitted payment stablecoin issuer’s Chief Financial Officer, or the individual performing an equivalent function, that the report is true and correct to the best of their knowledge and belief.  Under § 15.14(i)(3), the correctness of the report of financial condition is required to be attested to by the signatures of the directors and senior management of the permitted payment stablecoin issuer other than the officer, or the individual performing an equivalent function, making such declaration, with the attestation stating that the report has been examined by them and, to the best of their knowledge and belief, is true and correct.

Section 15.14(j) covers the submission of other reports requested by the OCC.  Upon request, all permitted payment stablecoin issuers are required to submit to the OCC a report on the financial condition of the permitted payment stablecoin issuer; the systems of the permitted payment stablecoin issuer for monitoring and controlling financial and operational risks; compliance of the permitted payment stablecoin issuer and any subsidiary thereof with the GENIUS Act, and 12 CFR part 15; and in the case of a Federal qualified nonbank payment stablecoin issuer, compliance of the permitted payment stablecoin issuer with the requirements of the Bank Secrecy Act and with laws authorizing the imposition of sanctions and implemented by the Secretary of the Treasury.

Section 15.14(k) sets forth ongoing compliance reporting.  Section 15.14(k)(1) provides that no later than 180 days after the approval of an application, as set forth in § 15.30, and on an annual basis thereafter, a permitted payment stablecoin issuer subject to OCC supervision is required to submit to the OCC a certification that the permitted payment stablecoin issuer has implemented anti-money laundering and economic sanctions compliance programs.  The programs are required to be reasonably designed to prevent the permitted payment stablecoin issuer from facilitating money laundering, specifically, facilitating money laundering for cartels and organizations designated as foreign terrorist organizations under section 219 of the Immigration and Nationality Act (8 U.S.C. 1189) and the financing of terrorist activities, consistent with the requirements of the GENIUS Act.  Section 15.14(k)(2) additionally requires that the initial certification be provided by the permitted payment stablecoin issuer’s board of directors. Subsequent certifications may be provided by the permitted payment stablecoin issuer’s Bank Secrecy Act officer, the board of directors, or an appropriate committee of the board of directors.

Section 15.14(l) sets forth audit requirements and requires a permitted payment stablecoin issuer with more than $50 billion in total consolidated outstanding issuance value, that is not subject to certain reporting requirements under the Securities Exchange Act of 1934, prepare, in accordance with GAAP, an annual financial statement.  Section 15.14(l)(2) sets forth the requirements for preparing and submitting the audited annual financial statements.  Section 15.14(l)(2)(ii) requires a permitted payment stablecoin issuer to submit the audited financial statements annually, within 120 days after the end of the permitted payment stablecoin issuer’s fiscal year, to the OCC.

Section 15.14(l)(2)(iii) provides that if a permitted payment stablecoin issuer is unable to timely file all or any portion of the audited annual financial statement required under § 15.14(l)(2)(ii), it must submit a written notice of late filing to the OCC.  The notice is required to disclose the permitted payment stablecoin issuer’s inability to timely file all, or specified portions, of its annual financial statement and the reasons therefore in reasonable detail; include the date by which the financial statement will be filed; and be filed on or before the deadline for filing the financial statement.

Section 15.14(m) sets forth notice requirements for changes in control of the permitted payment stablecoin issuer.  Under this section, a person seeking to acquire control of a permitted payment stablecoin issuer is required to follow the requirements of 12 CFR 5.50 as if the permitted payment stablecoin issuer were a national bank.

Section 15.15(b)(2) sets forth initial notice requirements for State qualified payment stablecoin issuers that are nonbank entities with a total consolidated outstanding issuance value of more than $10 billion.  Under the section, a State qualified payment stablecoin issuer with a total consolidated outstanding issuance value of more than $10 billion is required to provide written notification to the OCC within five calendar days after reaching such threshold.  The written notification is required to include: the State or States that currently regulate the State qualified payment stablecoin issuer; the State qualified payment stablecoin issuer’s outstanding issuance value as of the date of the notice; the date that the State qualified payment stablecoin issuer first reached the $10 billion total consolidated outstanding issuance value threshold; and an indication of whether and when the State qualified payment stablecoin issuer ceased issuing, on a net basis, new payment stablecoins and whether the State qualified payment stablecoin issuer intends to seek a waiver pursuant to § 15.15(d).

Section 15.15(b)(3) sets forth the capital analysis requirements for State qualified payment stablecoin issuers.  Under the section, within 270 days of reaching the $10 billion total consolidated outstanding issuance value threshold, a State qualified payment stablecoin issuer is required to submit a capital analysis to the OCC.  The analysis is required to include an analysis of the issuer’s current capital position and anticipated capital needs, sufficient to ensure ongoing operations, based on its business model and risk profile.  A State qualified payment stablecoin issuer is not required to submit a capital analysis if the issuer has received a waiver pursuant to § 15.15(d) or is not required to transition to the Federal regulatory framework pursuant to § 15.15(b)(1)(ii).

Section 15.15(b)(4) sets forth compliance notice requirements for a State qualified payment stablecoin issuer.  Under § 15.15(b)(4)(i), for purposes of complying with § 15.15(b)(1)(i), a State qualified payment stablecoin issuer is required to provide written notification to the OCC that it complies with the Federal regulatory framework under 12 CFR part 15 or, if the State qualified payment stablecoin issuer is not in compliance with the Federal regulatory framework under 12 CFR part 15, to provide written notice identifying the provisions with which the issuer does not comply, providing the issuer’s plan for remediating its noncompliance, and explaining why the issuer did not comply with the Federal regulatory framework within the 360-day transition period.  Under § 15.15(b)(4)(ii) a State qualified payment stablecoin issuer that does not cease issuing new payment stablecoins in accordance with § 15.15(b)(1)(ii) is required to transition to the regulatory framework under 12 CFR part 15 on the earlier of 360 days after reaching the $10 billion total consolidated outstanding issuance value threshold or the date on which the State qualified payment stablecoin issuer provides written notification under paragraph (b)(4)(i) of this section.

Section 15.15(d)(1)(i) requires a State qualified payment stablecoin issuer seeking to remain solely supervised by a State payment stablecoin regulator to submit to the OCC a written waiver request containing information necessary to evaluate such request under §§ 15.15(d)(2) and (3).  In addition, § 15.15(d)(1)(ii) provides that a State qualified payment stablecoin issuer seeking to remain solely supervised by a State payment stablecoin regulator is required to submit a waiver request within 240 days of reaching the $10 billion total consolidated outstanding issuance value threshold.

Section 15.30(a)(1) sets forth application requirements for insured national banks, Federal savings associations, and insured Federal branches.  This section provides that any insured national bank, Federal savings association, or insured Federal branch that seeks to issue payment stablecoins through a subsidiary is required to file an application under this section and receive prior approval from the OCC before the subsidiary may issue payment stablecoins.

Section 15.30(a)(2) sets forth application requirements for nonbank entities, uninsured national banks, and uninsured Federal branches.  This section provides that any nonbank entity, uninsured national bank, or uninsured Federal branch that seeks to issue payment stablecoins as a Federal qualified payment stablecoin issuer is required to file an application under this section and receive prior approval from the OCC before issuing payment stablecoins. 

Section 15.30(b) sets forth the application process for insured national banks, Federal savings associations, insured Federal branches and nonbank entities, uninsured national banks, and uninsured Federal branches that seek to issue payment stablecoins.  The process would require an applicant to submit all the information required by the form for an application under this section.  The forms and instructions are available on the OCC’s website.  Each director, executive officer, and principal shareholder of the applicant (or in the case of an applicant that is an insured national bank, Federal savings association, or insured Federal branch, of the subsidiary of the applicant) is required to submit the information prescribed in the Interagency Biographical and Financial Report and Corporate Background and Financial Report,5 available at the OCC’s website.  An applicant is required to certify that any filing or supporting material submitted to the OCC contains no material misrepresentations or omissions.  An applicant is also required to certify whether section 4(a)(12) of the GENIUS Act (12 U.S.C. 5903(a)(12)) applies to the applicant.  The process provides that an applicant should address an application under this section to the appropriate OCC licensing office, unless the OCC advises an applicant otherwise.  The OCC will consider an application substantially complete if it contains sufficient information for the OCC to render a decision on whether the applicant satisfies the factors set forth in § 15.30(d).  The OCC will notify applicants not later than 30 days after receipt of an application whether the application is substantially complete.  If the application is not substantially complete, the OCC will notify the applicant of the information required in order for the application to be substantially complete.

Section 15.30(f) sets forth the OCC’s appeal process following the agency’s denial of a substantially complete application.  Section 15.30(f)(1) provides that an applicant may request a hearing to appeal the OCC’s denial of a substantially complete application within 30 days of receipt of the OCC’s notice of denial.  The request for a hearing is required to be in writing.  The applicant may request the hearing be on the written record, oral testimony and oral argument, or both.  Section 15.30(f)(3) further provides that if filing a written appeal, the applicant must submit in writing all documents and arguments that the applicant wishes to be considered.

Section 15.30(g)(1) provides that an insured national bank, Federal savings association, or insured Federal branch that has a pending substantially complete application for a subsidiary to become a permitted payment stablecoin issuer may request that the OCC waive the requirements of the GENIUS Act (12 U.S.C. 5901 et seq.) or part 15 with respect to that subsidiary.  The requests are required to be in writing.

Section 15.30(g)(2) provides that a nonbank entity, uninsured national bank, or uninsured Federal branch that has a pending substantially complete application to become a Federal qualified payment stablecoin issuer may request that the OCC waive the requirements of the GENIUS Act (12 U.S.C. 5901 et seq.) or part 15 with respect to that entity.  The requests are required to be in writing.

Section 15.31(a) provides that a foreign payment stablecoin issuer is not subject to the prohibitions of section 3 of the GENIUS Act (12 U.S.C. 5902) if it meets all the requirements provided in the paragraph.  Section 15.31(a)(3)(ii)(D)(1) provides, as a condition of one of several methods of complying with § 15.31(a)(3)(i), a requirement for a foreign payment stablecoin issuer to submit for the OCC’s prior approval a detailed proposal to meet the requirements of § 15.31(a)(3)(i).

Section 15.31(b)(2) sets forth reporting requirements for foreign payment stablecoin issuers registered with the OCC.  Section 15.31(b)(2)(i) provides that a foreign payment stablecoin issuer registered with the OCC pursuant to § 15.32 is required to produce the reports required of a permitted payment stablecoin issuer under § 15.14 as well as any other reports the OCC may require.  Section 15.31(b)(2)(ii) further provides that a foreign payment stablecoin issuer may request, in writing, an exemption from any reporting requirement that would otherwise apply under § 15.14.  The OCC may grant an exemption in its sole discretion.

Section 15.32(a) sets forth application requirements for a foreign payment stablecoin issuer.  This section provides that a foreign payment stablecoin issuer that seeks to be registered with the OCC under section 18(c) of the GENIUS Act (12 U.S.C. 5916(c)) is required to file an application under this section.

Section 15.32(b) sets forth the application process for a foreign payment stablecoin issuer that seeks to be registered with the OCC under section 18(c) of the GENIUS Act (12 U.S.C. 5916(c)).  The process requires an applicant to provide all the information required by the form for an application under this section; evidence that the Secretary of the Treasury has determined that the applicant is subject to a regulatory and supervisory regime comparable to the GENIUS Act with respect to payment stablecoins, under section 18 of the GENIUS Act (12 U.S.C. 5916); a certification that the applicant will make available to the OCC all information that the OCC deems necessary to determine and enforce compliance with the GENIUS Act and 12 CFR part 15; the applicant’s consent to United States jurisdiction relating to enforcement of the GENIUS Act and 12 CFR part 15; certification that any filing or supporting material submitted to the OCC contains no material misrepresentations or omissions; and certification as to the applicability of section 4(a)(12) of the GENIUS Act (12 U.S.C. 5903(a)(12)).  The process provides that an applicant should address an application under this section to the appropriate OCC licensing office, unless the OCC advises an applicant otherwise.  The forms and instructions will be available on the OCC’s website.

Section 15.32(e) sets forth the conditions of approval for foreign payment stablecoin issuers seeking to be registered with the OCC under section 18(c) of the GENIUS Act (12 U.S.C. 5916(c)).  Section 15.32(e)(3)(i) requires a foreign payment stablecoin issuer to provide evidence that it complies with § 15.31(a) by providing to the OCC, by noon on the last day of each month, a report describing the total number of outstanding payment stablecoins issued by the foreign payment stablecoin issuer held by United States customers and the amount and composition of the foreign payment stablecoin issuer’s reserves, including their geographic location and average tenor of reserve instruments.  Additionally, § 15.32(e)(3)(ii) requires the report to use a format like the template provided in Table 1 to § 15.32(e)(3)(ii).  Section 15.32(e)(3)(iii) requires the foreign payment stablecoin issuer to promptly notify the OCC through its supervisory office on any day in which the issuer fails to meet the reserve asset requirements of § 15.32(e)(3).

Section 15.32(g) sets forth the OCC’s appeal of rejection processes for foreign payment stablecoin issuers.  A foreign payment stablecoin issuer may request a hearing to appeal the OCC’s rejection of an application for registration within 30 days of receipt of the OCC’s notice of rejection.  Section 15.32(g)(2) requires the request for a written or oral hearing to be in writing.  Under § 15.32(g)(3), the foreign payment stablecoin issuer may request the hearing be on the written record, oral testimony and oral argument, or both.  Section 15.32(g)(5) further provides that if filing a written appeal, the foreign payment stablecoin issuer must submit in writing all documents and arguments that the applicant wishes to be considered.
Section 15.40(c) describes operational backstop debt which may consist of debt instruments in an amount that in total does not exceed 50 percent of the operational backstop requirement in § 15.41(b) and where each debt instrument meets specific criteria.  Under § 15.40(c)(5), a debt instrument may be callable by its terms only after a minimum of five years after issuance and only with prior approval of the OCC.  In addition, the permitted payment stablecoin issuer is required to either replace the instrument to be called with an equivalent amount of a new instrument meeting the criteria for operational backstop debt or demonstrate to the OCC that the permitted payment stablecoin issuer has sufficient capital to meet its minimum capital requirement in § 15.41.

Section 15.41 sets forth minimum capital and backstop requirements for permitted payment stablecoin issuers.  Section 15.41(b)(1)(iii) provides that a permitted payment stablecoin issuer may exclude one-time expenses that are wholly unrelated to the continuing operation of the permitted payment stablecoin issuer from the calculation under §§ 15.41(b)(1)(i) or (ii) with prior written approval of the OCC.

Section 15.41(c)(1)(i) requires a permitted payment stablecoin issuer to notify the OCC within 24 hours if it fails to meet either the minimum capital or backstop requirement during a quarter.  Section 15.41(c)(1)(ii) further instructs a permitted payment stablecoin issuer to publicly report whether it has complied with the minimum capital and backstop requirements during the quarter on the report required under § 15.14.6

Section 15.41(d) sets forth uninsured national trust banks’ minimum capital requirements.  Under § 15.41(d)(1), an uninsured national trust bank, whether or not it is a permitted payment stablecoin issuer, may elect to comply with all of the requirements in §§ 15.40 through 15.42 in lieu of complying with the requirements in 12 CFR part 3 upon receipt of the OCC’s prior approval.  Section 15.41(d)(2) instructs that, to make the election described in § 15.41(d)(1), an uninsured national trust bank must submit a written request for prior approval to the appropriate OCC supervisory office, along with documentation sufficient to support the bank’s minimum capital and operational backstop amounts.  Section 15.41(d)(4) further provides that an uninsured national trust bank may rescind an approved election under § 15.41(d) by submitting a notice to the appropriate OCC supervisory office.

Section 15.42 sets forth individual additional capital or operational backstop requirements for permitted payment stablecoin issuers.  Section 15.42(c)(2)(i) provides that a permitted payment stablecoin issuer may respond to any or all of the items in the notice sent by the OCC notifying the permitted payment stablecoin issuer in writing of the proposed additional capital or backstop requirement and the date by which it should be reached (if applicable).  The response is required to be in writing and delivered to the OCC within 30 days after the date on which the permitted payment stablecoin issuer received the notice or such other time period as the OCC determines appropriate based on the condition of the permitted payment stablecoin issuer.
Section 15.42(c)(3) sets forth the OCC’s decision process in determining whether the individual additional capital or backstop requirement should be established for a permitted payment stablecoin issuer and, if so, the requirement and the date the requirement will become effective.  Section 15.42(c)(4) provides that the OCC’s decision may require the permitted payment stablecoin issuer to develop and submit to the OCC, within a time period specified, an acceptable plan to reach the additional capital or backstop requirement established for the permitted payment stablecoin issuer by the date required.

Recordkeeping Requirements

Section 15.11(a)(1) requires a permitted payment stablecoin issuer to maintain reserve assets that are identifiable, are segregated from and not commingled with other assets owned or held by the permitted payment stablecoin issuer, at all times have a reserve asset value that equals or exceeds the outstanding issuance value of the permitted payment stablecoin issuer, and are either held directly by the permitted payment stablecoin issuer or within the custody of an eligible financial institution.

Section 15.11(f)(1) requires a permitted payment stablecoin issuer to, each month, have the information disclosed in the previous month-end report required under § 15.11(e) examined by a registered public accounting firm.  Section 15.11(f)(2) requires that each month, the Chief Executive Officer and Chief Financial Officer (or the persons performing the equivalent functions) of a permitted payment stablecoin issuer submit to the OCC a certification that the monthly report required under § 15.11(e) is accurate.

Section 15.12(c) requires a permitted payment stablecoin issuer’s redemption policy to provide clear and conspicuous procedures for timely redemption of outstanding payment stablecoins.  Timely redemption may not exceed two business days following the date of the requested redemption and any discretionary limitations on timely redemptions can only be imposed by the OCC or, in the case of a State qualified payment stablecoin issuer, by the OCC, Board, or the State payment stablecoin regulator, as applicable.

Section 15.13(a)(1) covers internal controls and information systems.  A permitted payment stablecoin issuer is required to have internal controls and information systems to support effective risk management that are appropriate for the size and complexity of the permitted payment stablecoin issuer and the nature, scope, and risk of its activities.  The internal controls are required to provide for: an organizational structure that establishes clear lines of authority and responsibility for monitoring adherence to established policies, including appropriate segregation of duties and dual controls; effective risk assessment; timely and accurate financial, operational, and regulatory reporting, including with respect to the reports required under 12 CFR part 15; adequate procedures to monitor, safeguard, manage, control, and monetize assets, including reserve assets; and compliance with applicable laws and regulations.

Section 15.13(a)(2) covers internal audit systems.  A permitted payment stablecoin issuer is required to have an internal audit system that is appropriate to the size and complexity of the permitted payment stablecoin issuer and the nature, scope, and risk of its activities.  The internal audit system is required to provide for adequate monitoring of the system of internal controls through an internal audit function or if the size, complexity, or scope of operations of the permitted payment stablecoin issuer does not warrant a full-scale internal audit function, a system of independent reviews of key internal controls.  Additionally, the internal audit system is required to provide: independence and objectivity; qualified persons responsible for the audit function; and adequate independent testing and review of internal controls and information systems, verification of published information available to customers, calculations for required reserves, and regulatory filings.  The internal audit system must also provide for adequate documentation of tests and findings and any corrective actions; verification and review of management actions to address deficiencies; and review by the permitted payment stablecoin issuer’s audit committee or board of directors of the effectiveness of the internal audit systems.

Section 15.13(a)(5) requires a permitted payment stablecoin issuer to establish and maintain a system that is commensurate with the permitted payment stablecoin issuer’s size and complexity and the nature and scope of its operations to evaluate and monitor earnings and ensure that earnings are sufficient to support operations and maintain the capital levels required by subpart E of 12 CFR part 15.

Section 15.13(a)(6)(i)(D) requires that a permitted payment stablecoin issuer ensure that transactions between the permitted payment stablecoin issuer and insiders or affiliates alone, or in the aggregate, are appropriately documented and reviewed by the board of directors.

Section 15.13(a)(10)(ii)(D) requires a permitted payment stablecoin issuer to have in place policies and procedures that appropriately manage its foreign exchange risk and any attendant risks, including risks related to the posting or collection of margin, foreign exchange counterparties, and basis risk.  The policies and procedures must include adherence to §§ 15.13(a)(10)(iii) and (iv). 

Section 15.13(b) covers information technology and security programs.  Section 15.13(b)(1) requires a permitted payment stablecoin issuer to implement a comprehensive written information security risk and control framework, including a program that assesses and manages information technology and information security risks.  Section 15.13(b)(2) requires the board of directors or an appropriate board committee to approve the information technology and security program and oversee the development, implementation, and maintenance of the program, including the appointment of a qualified individual responsible for the program.  Such oversight includes assigning specific responsibility for program implementation and review of program-related reports.  Section 15.13(b)(3) requires a permitted payment stablecoin issuer’s information technology and security program include: an inventory and classification of assets, processes, and sensitivity of data; controls supporting and safeguarding sensitive information and processes; evaluation, validation, and reporting processes to ensure that key information technology systems and controls, including smart contracts, are operating as intended; periodic independent testing; and a comprehensive and effective incident identification and assessment process and incident response program.  Section 15.13(b)(4) requires that a permitted payment stablecoin issuer’s information technology and security program includes administrative, technical, and physical safeguards designed to ensure the security and confidentiality of records containing nonpublic personal information about a customer or sensitive customer information.  The program must also protect against any anticipated threats or hazards to the security or integrity of such records, protect against unauthorized access to or use of such records that could result in substantial harm or inconvenience to any customer, and to ensure the proper disposal of such records.  Section 15.13(b)(6)(i) provides that a permitted payment stablecoin issuer must monitor any relevant changes in technology, the sensitivity of its customer information, internal or external threats, and the permitted payment stablecoin issuer’s own changing business arrangements, such as mergers and acquisitions, alliances and joint ventures, third-party arrangements, and changes to applicable information systems.  Under § 15.13(b)(6)(ii), a permitted payment stablecoin issuer is required to evaluate and adjust its information technology and security program, as appropriate, based on the monitoring required by § 15.13(b)(6)(i).  Finally, § 15.13(b)(8) requires a permitted payment stablecoin issuer’s information technology and security program include measures to ensure continuity of operations and recovery of critical functions, including by conducting business impact analyses, testing for vulnerabilities, and testing with critical service providers.

Section 15.13(b)(5) requires a permitted payment stablecoin issuer to develop, implement, and maintain appropriate measures to ensure secure handling of digital assets, including private key management, backup, and recovery incorporating: (i) relevant technical, operational, strategic, market, legal, and compliance considerations relating to each digital asset and its underlying ledger; and (ii) material developments specifically related to supported digital assets and their underlying ledgers.7

Section 15.14(f) requires all permitted payment stablecoin issuers to maintain a complete set of books and records in English.

Section 15.14(g) requires all permitted payment stablecoin issuers to develop and implement a records retention policy that ensures the permitted payment stablecoin issuer can demonstrate compliance with the GENIUS Act, 12 CFR part 15, and all applicable laws and regulations.

Section 15.14(l)(1) requires a registered public accounting firm to perform an audit of the financial statements described in § 15.14(l) and sets forth the auditing requirements.

Section 15.15(b) covers the requirements related to a State qualified payment stablecoin issuer that is a nonbank entity transitioning to the OCC’s regulatory framework pursuant to section 4 of the GENIUS Act (12 U.S.C. 5903).  Sections 15.15(b)(1)(i) and (ii) require a State qualified payment stablecoin issuer with a total consolidated outstanding issuance value of more than $10 billion to no later than 360 days after reaching such threshold, transition to the Federal regulatory framework under 12 CFR part 15 and comply with the provisions of this part applicable to Federal qualified payment stablecoin issuers or cease issuing, on a net basis, new payment stablecoins until the issuer is under the $10 billion total consolidated outstanding issuance value threshold.  Additionally, § 15.15(b)(4)(ii) provides that a State qualified payment stablecoin issuer that does not cease issuing new payment stablecoins in accordance with § 15.15(b)(1)(ii) would be required to transition to the regulatory framework under this part on the earlier of 360 days after reaching the $10 billion outstanding issuance value threshold or the date on which the State qualified payment stablecoin issuer provides written notification under § 15.15(b)(4)(i).

Section 15.21 sets forth covered asset custodial property requirements.  Section 15.21(b)(1) provides that a covered custodian is required to take appropriate steps to protect the covered assets of covered customers from the claims of creditors of the covered custodian and any sub-custodian, as applicable, through adopting, implementing, and maintaining written custody agreements and policies, procedures, and internal controls that are adequate to comply with applicable law and that are commensurate with the covered custodian’s size, complexity, and risk profile and with the nature of the applicable covered assets for which it provides custodial services or safekeeping services.  Section 15.21(b)(2)(i) further provides that a covered custodian may maintain the covered assets of a covered customer through the use of a sub-custodian if consistent with applicable law, provided that the covered custodian maintains adequate safeguards and internal controls reasonably designed to provide the covered custodian with oversight of the sub-custodian’s compliance with the requirements of 12 CFR part 15, subpart C.

Section 15.22 sets forth the use of omnibus accounts.  Under § 15.22(c), a sub-custodian may, for convenience, commingle the covered custodian’s assets with the covered assets of its covered customers in one or more omnibus accounts of the sub-custodian; provided that the covered custodian maintains adequate safeguards and internal controls reasonably designed to ensure that the sub-custodian segregates all covered assets of the covered custodian’s covered customers from, and does not commingle such covered assets with, the assets of the sub-custodian.

Section 15.41(a)(2)(ii) requires a permitted payment stablecoin issuer to have a process for assessing its overall capital adequacy in relation to its business model and risk profile and a comprehensive strategy for sustaining an appropriate level of capital to maintain ongoing operations.

Section 15.41(c)(5) provides that among other criteria, the OCC may permit a permitted payment stablecoin issuer to continue operations while its operational backstop is below the required amount, if the permitted payment stablecoin issuer provides a plan within seven days to regain compliance with the operational backstop requirement within 90 days, and the OCC deems the plan viable.

Disclosure Requirements

Section 15.11(e) sets forth the specific disclosure requirements for composition reports.  Section 15.11(e)(1) requires a permitted payment stablecoin issuer by noon on the last day of each month, to publish on the website of the issuer the monthly composition of the issuer’s reserves held pursuant to the GENIUS Act as of noon on the last day of the previous month. 

Section 15.12(b) requires a permitted payment stablecoin issuer to publicly disclose its redemption policy and include: the timeframe in which the issuer will redeem payment stablecoins and the timeframe under which the issuer is required to redeem payment stablecoins under § 15.12(c)(1)(i); a statement explaining the limitation in § 15.12(c)(1)(ii); a statement explaining the scenarios under which the redemption period may be extended as described in § 15.12(d); a statement with clear instructions on how a payment stablecoin holder can redeem a payment stablecoin, including a link to the website(s) where a payment stablecoin holder can redeem the payment stablecoin; and the minimum number of payment stablecoins, if any, that the permitted payment stablecoin issuer will redeem, provided that the issuer must redeem any number greater than or equal to one payment stablecoin, subject to appropriate customer screening and onboarding.

Section 15.12(e) sets forth purchase and redemption disclosures and fee requirements.  Section 15.12(e)(1) requires a permitted payment stablecoin issuer to publicly, clearly, and conspicuously disclose in plain language and in a format that is readily noticeable to payment stablecoin holders, and segregated from other information: the name of the permitted payment stablecoin issuer that issues the payment stablecoin; that the permitted payment stablecoin issuer is the entity that is obligated to convert, redeem, or repurchase the payment stablecoin for a fixed amount of monetary value; the website that contains a link to the monthly composition report of the relevant permitted payment stablecoin issuer’s reserves required under § 15.11(e); all fees associated with purchasing or redeeming payment stablecoins; that the payment stablecoin is not legal tender, issued by the United States, or guaranteed or approved by the United States; and that payment stablecoins are not deposits, not backed by the full faith and credit of the United States, not subject to deposit insurance by the FDIC, and not subject to share insurance by the National Credit Union Administration.  Additionally, § 15.12(e)(2) requires the permitted payment stablecoin issuer to update the disclosures in § 15.12(e)(1)(iv) if there are any changes in fees associated with purchasing or redeeming payment stablecoins and provide payment stablecoin holders at least seven calendar days’ prior notice of the change, including by delivering the notice to customers with whom the permitted payment stablecoin issuer has a current relationship.  Section 15.12(e)(3) also requires a permitted payment stablecoin issuer to publish the disclosures in § 15.12(e)(1) and any updates made in accordance with § 15.12(e)(2) on the permitted payment stablecoin issuer’s website.  Section 15.12(e)(4) also requires the permitted payment stablecoin issuer to include the disclosures in § 15.12(e)(1) and any updates made in accordance with § 15.12(e)(2) in any customer agreements.

Section 15.14(l) requires that the described annual financial statement includes the disclosure of any related party transactions, as defined by GAAP.

Section 15.14(l)(2)(i) requires a permitted payment stablecoin issuer to make the audited financial statements under § 15.15(14)(l), publicly available on the permitted payment stablecoin issuer’s website.

Section 15.22(b) provides that a covered custodian may, for convenience, commingle the covered assets of multiple covered customers in one or more omnibus accounts to the extent that the steps it has taken pursuant to § 15.21(b) are adequate to maintain safe and sound practices for the use and terms of any omnibus account, and to the extent that the use of omnibus accounts is consistent with applicable law, and is fully disclosed in the applicable custody agreement.
Section 15.32(e) sets forth the conditions of approval for foreign payment stablecoin issuers seeking to be registered with the OCC under section 18(c) of the GENIUS Act (12 U.S.C. 5916(c)).  Sections 15.32(e)(1) and (2) provide that upon request by the OCC, foreign payment stablecoin issuers are required to grant the OCC prompt and complete access to all officers, directors, employees, and agents and to all relevant books, records, or documents of any type, in a form and location accessible to the OCC in the United States.  The foreign payment stablecoin issuer is also required to make all information available to the OCC in English.

3. Consideration of the use of improved information technology:

The OCC uses information technology to reduce compliance burden for entities that would be subject to part 15 and the OCC.  The rule includes provisions regarding ongoing monitoring intended to reduce the need for other supervisory methods that may entail additional burden.

4. Efforts to identify duplication:

The rule states that the OCC will, to the fullest extent possible avoid duplication of examination activities, reporting requirements, and requests for information.  The rule further states that the OCC will use existing reports and other supervisory information to the fullest extent possible.  Consistent with this approach, for example, the rule provides that certain permitted payment stablecoin issuers and foreign issuers that otherwise would be required to submit a notice under § 15.14(m) would not need to do so if the OCC received the required information pursuant to notices filed under 12 CFR part 5 or § 15.30. 

5. Methods used to minimize burden if the collection has an impact on small entities:

At this time, the OCC does not anticipate that the rule will have a significant impact on small entities.  The rule seeks to minimize burden on all entities to which the rule would apply, and certain requirements would apply only to issuers with total outstanding issuance in excess of $10 billion or $50 billion.

6. Consequences to the Federal program if the collection was conducted less frequently:

The timeline for certain requirements, e.g., that in § 15.14(k), are mandated by statute.  For other information collections the OCC has determined that the frequency of collection is necessary to adequately supervise permitted payment stablecoin issuers and foreign payment stablecoin issuers. 

7. Special circumstances necessitating the collection to be conducted in a manner inconsistent with 5 CFR part 1320:

The information collection is conducted in accordance with the requirements of 5 CFR part 1320.

8. Efforts to consult with persons outside the agency:

The OCC issued a notice of proposed rulemaking for the collection in the Federal Register March 2, 2026 (91 FR 10202).  The agency received several comments regarding the rules’ reporting, recordkeeping, and disclosure requirements.  Commenters urged the OCC to adopt a reporting framework that maintains regulatory differentiation between bank and nonbank stablecoin issuers.  The commenters stated that bank-affiliated issuers should be permitted to satisfy stablecoin-specific reporting obligations through streamlined, integrated disclosures—such as supplemental schedules to Call Reports, while nonbank issuers should be subject to more robust, standalone reporting and audit requirements commensurate with their risk profile and lack of prudential supervision.  Commenters stated that this approach would preserve safety and soundness, promote regulatory consistency, and support community bank participation in stablecoin activities without disadvantaging institutions that already operate under a rigorous supervisory framework.

After careful consideration of the comments, the OCC has determined that all permitted payment stablecoin issuers should be subject to uniform reporting requirements.  This approach ensures that the OCC receives a consistent set of data across all permitted payment stablecoin issuers.  As discussed, the OCC considered the information to be collected to be an appropriate minimum amount of data for permitted payment stablecoin issuers.  The receipt of this data will also allow the OCC to calibrate its supervisory approach to each permitted payment stablecoin issuer and minimize supervisory disruptions associated with limited and full-scope examinations.  Moreover, reporting consistency should help the OCC ensure comparability and better facilitate market oversight.

A few commenters urged the OCC to focus reporting on primary market data, including primary market issuance, redemption activity, and reserve composition.  One commenter emphasized that the proposed weekly reporting should focus on primary market data instead of secondary market data.  The commenters added that, if the OCC does require secondary market reporting, the data collected should focus on material secondary market indicators relevant to prudential supervision and market integrity.  Some of the commenters also noted the challenges with reporting secondary market data since market activity occurs across multiple venues and through intermediaries where the permitted payment stablecoin issuer may lack full visibility.  The OCC will consider this comment in conjunction with comments received on the draft reporting forms and revise the final forms accordingly.

One commenter stated that a permitted payment stablecoin issuer’s reporting and risk management obligations are overly focused on primary market activity—i.e., issuance and redemption of payment stablecoins directly between the issuer and its customers.  The commenter claimed that this creates two distinct and serious gaps that the final rule should address: one in safety and soundness oversight and one in illicit finance compliance.  The commenter stated that permitted payment stablecoin issuers should be required to submit reporting when secondary market prices move below $1.00 and implement a real-time secondary market transaction monitoring program to detect unusual activity and report anomalies to the OCC.  The OCC will consider this comment along with the comments received on the draft reporting forms when deciding what modifications should be made in the final forms with respect to secondary market data.
One commenter stated that the proposed categories of information in the reporting forms would not require information about the protocol or set of protocols on which the stablecoins are deployed.  The commenter added that the weekly reporting forms should, at a minimum, include a list of protocols on which the permitted payment stablecoin issuer’s stablecoins are deployed above a certain threshold.  The same commenter further added that the OCC should impose a similar reporting requirement for tokenized reserves.  The OCC will consider this comment along with comments received on the draft reporting forms when finalizing the reporting forms.

One commenter recommended that the agency consider including a broader set of quality indicators in the final rule.  The commenter proposed including peg stability, price integrity, liquidity depth, exit feasibility, holder concentration, technical risk, and network and infrastructure dependencies.

Several commenters stated that the OCC should require all reporting forms for weekly, monthly, and quarterly reporting to be in a standardized, machine-readable format, including eXtensible Business Reporting Language (commonly known as “XBRL”) or ISO 20022-aligned structures.  The commenters generally stated that requiring reporting in a machine-readable format would allow for efficiencies including automated data extraction and the ability to easily compare reporting across permitted payment stablecoin issuers.

On June 25, 2026, pursuant to the Financial Data Transparency Act (FDTA),8 the OCC and other Federal agencies issued a joint final rule establishing joint data standards.9  In addition to the joint rule, the FDTA also directs each agency to issue individual rules adopting applicable joint standards for certain collections of information under their respective purview.  The OCC has not issued its agency-specific rulemaking adopting applicable joint standards.  In developing and finalizing the weekly, monthly, and quarterly reporting forms, the OCC will ensure that the reporting forms are consistent with the FDTA and the agencies’ joint rule.  Of note, the OCC will be able to accept some ISO 20022 structures, such as eXtensible Markup Language (commonly known as ‘‘XML’’).

The agency received several comments concerning whether the agency should implement real-time reporting.  A few commenters expressed support for real-time reporting.  One commenter noted that some relevant data exists on-chain and can be extracted in real time.  Another commenter stated that the implementation of real-time reporting could meaningfully reduce the frequency of on-site examinations.

Conversely, several commenters opposed the adoption of real-time reporting and stated that it should not be required in the final rule.  The commenters generally claimed that real-time reporting would be unnecessary or overly burdensome.  One commenter stated that while permitted payment stablecoin issuers may track certain data in real time, translating such data into a form ready for supervisory reporting often requires reconciliation, validation, and normalization processes that would make real-time external reporting unnecessarily burdensome.  Another commenter stated that some data fields are not observable in real time and that a weekly reporting cadence is more aligned with the operational rhythm already used by issuers.  Another commenter stated that a weekly reporting cadence is preferable to real-time reporting and suggested that the weekly reporting framework could be supplemented with event-driven reporting.

Upon consideration, the OCC has declined to incorporate a real-time reporting component into the reporting framework for permitted payment stablecoin issuers.  The OCC has determined that a weekly and quarterly reporting cadence will provide the agency with sufficient data and supervisory visibility into the stablecoin market.  Further, the agency is sensitive to the increased operational expense and burden that the implementation of real-time reporting would impose on permitted payment stablecoin issuers.  For these reasons, the OCC has declined to impose a real-time reporting requirement on permitted payment stablecoin issuers.  The OCC may reconsider this position in the future if, for example, effective supervision of the stablecoin market demands the implementation of real-time reporting or future technological advances mean that implementing real-time reporting would not be overly burdensome for permitted payment stablecoin issuers.

A few commenters stated that the OCC should publish and solicit comment on the weekly and quarterly reporting forms and instructions referenced in the proposal in advance of finalizing the reporting forms.  On June 12, 2026, the OCC published the weekly and quarterly reporting forms and instructions and requested public comment on the forms and their instructions (91 FR 35795).  The OCC will consider the comments on these forms, as well as those described above, when finalizing the reporting forms for permitted payment stablecoin issuers.

One commenter stated that the OCC should specify the reporting categories and their required level of detail in the rule text itself.  The commenter expressed concern that if the reporting categories and the required level of detail are not included in the rule, the OCC could modify the reporting forms without proceeding through the formal rulemaking process, which would include notice and comment.

The final rule does not incorporate or specify the reporting fields or the required level of detail.  Inclusion of such language is unnecessary to provide the public with prior notice and opportunity to comment on the reports.  As with the proposed reporting forms, the agency has solicited public comments on both the reporting framework (i.e., weekly and quarterly reporting) through the notice of proposed rulemaking on March 2, 2026 (91 FR 10202) and the reporting forms and instructions, which the agency published on June 12, 2026.  In both adopting and amending the reporting forms, the OCC will adhere to administrative laws and regulations, including the Paperwork Reduction Act.

Weekly Reports (§ 15.14 (h))

As discussed above, proposed § 15.14(h) would have required all permitted payment stablecoin issuers to submit a confidential weekly report to the OCC in the manner and form specified by the agency.  Under the proposal, a permitted payment stablecoin issuer would have been required to provide information regarding stablecoin issuance and redemption, trading volume, and reserve assets for each payment stablecoin it issues.  The report would have included information relating to the blockchains on which the payment stablecoin operates, outstanding issuance value, secondary market activity and price movements, redemption volume and timing, detailed information regarding reserve assets, and other relevant information.  As discussed above, the agency published the weekly and quarterly reporting forms for notice and public comment on June 12, 2026.  The following discussion includes comments received in response to the proposal's issuance on March 2, 2026, and the weekly reporting forms and instructions’ issuance on June 12, 2026.

A few commenters expressed support for the weekly reporting cadence on the grounds that the reporting framework is generally well calibrated and directionally appropriate.  However, the commenters also expressed a desire for the OCC to narrow the data fields to categories more closely tied to the statutory requirements and prudential oversight.  For example, commenters recommended recalibrating the data fields to focus on liquidity, reserve management, and redemptions.

Several commenters also expressed opposition to the weekly reporting requirement.  Generally, the commenters opposed the weekly reporting requirement on the grounds that it is overly burdensome, particularly for smaller issuers.  In some cases, the commenters questioned the supervisory value of weekly reporting.  The commenters also expressed a preference for a variety of reporting alternatives, including monthly reporting, monthly reporting accompanied by event-triggered reporting, and quarterly confidential reporting in addition to quarterly public reporting.  One commenter added that if the OCC adopts weekly reporting, the data fields should be limited to the core data fields necessary to monitor a permitted payment stablecoin issuer for safety and soundness.

Under proposed § 15.14(h), the weekly reporting submitted to the OCC would have been confidential.  One commenter expressed the view that stablecoin holders would benefit from having access to weekly reporting and encouraged the OCC to make the weekly reporting available to the public.  Two commenters opposed the disclosure of weekly data on the grounds that it could create market distortions, reveal commercially sensitive information, and risk encouraging short-term market reactions to normal operational fluctuations that do not reflect underlying prudential concerns.  Further, the commenters stated that disclosures should be focused on statutorily required disclosures such as reserve composition.  One of the commenters expressed an openness to the disclosure of aggregated statistics on payment stablecoin issuance and volumes, among other things, for payment stablecoins.

One commenter stated that the weekly reporting under proposed § 15.14(h) is not designed to identify protocol-level exposure.  Specifically, the commenter stated that the data fields enumerated in proposed § 15.14(h) are appropriate for entity-level reserve and redemption oversight, but do not capture the protocol deployment of stablecoin-denominated assets where systemic risk is concentrated.

Several commenters opposed the OCC's proposed weekly collection of “the 100 persons that hold or trade the stablecoin the most.”  Commenters generally opposed the collection of this information on several grounds.  First, commenters stated that the OCC has not articulated a clear supervisory rationale for collecting this data and that this information is not essential to understanding a permitted payment stablecoin issuer’s operations.  Second, commenters claimed that issuers cannot reliably produce this data because payment stablecoins frequently trade through exchanges and intermediaries, which limits permitted payment stablecoin issuers’ ability to reliably identify the top 100 holders on a recurring basis.  Finally, the commenters claimed that the required disclosure of top-holder information raises significant privacy concerns.  Several commenters presented solutions ranging from removing the collection of this data from the weekly reporting form to focusing the collection on the top 100 wallets, which would not include any beneficial ownership information.

Upon review of the comments, the OCC intends to keep the weekly reporting confidential.  The agency believes that the confidentiality of this reporting serves the interest of promoting the exchange of supervisory information between permitted payment stablecoin issuers and the OCC.  In the future, the OCC may consider publishing a limited set of data if it would be useful to the public.  For example, the OCC may consider publishing a limited set of aggregate statistics based on the weekly reporting.  The OCC published a draft weekly reporting form for comment that requests information on the top 100 payment stablecoin wallet addresses, not information identifying the top 100 individual persons holding payment stablecoins of an issuer (91 FR 35795).  The OCC believes the collection of this information will provide important supervisory data points related to concentration risk, payment stablecoin volatility, and other payment stablecoin characteristics that are important to the OCC's supervision of permitted payment stablecoin issuers.  The OCC plans to make adjustments to the reporting forms as appropriate to address comments received, as the market develops, and as the OCC gains experience supervising permitted payment stablecoin issuers.

Quarterly Reports (§ 15.14(i))

As discussed above, proposed § 15.14(i) would have required all permitted payment stablecoin issuers to submit a quarterly report of financial condition within 30 days after the end of the prior quarter and in a standardized format prescribed by the OCC.  Under the proposal, permitted payment stablecoin issuers would have been required to submit quarterly reports of financial condition to the OCC, including, but not limited to, an income statement, expenses, balance sheet, reserves, changes in equity, investments, capital, outstanding issuance value, and assets under custody, in a standardized format.  The agency published the weekly and quarterly reporting forms for notice and public comment on June 12, 2026 (91 FR 35795).  The following discussion includes comments received in response to the proposal’s issuance on March 2, 2026 (91 FR 10202).

A few commenters expressed support for requiring permitted payment stablecoin issuers to provide quarterly reports of financial condition.  The commenters generally stated that quarterly reporting is an important tool to both compare permitted payment stablecoin issuers and prevent the deterioration of market confidence.

Several commenters stated that permitted payment stablecoin issuers that are subsidiaries of national banks that already file Call Reports should not be required to submit a separate quarterly report in order to minimize duplicative reporting requirements, reduce reporting burden, and lower compliance costs.  The commenters generally advocated that these permitted payment stablecoin issuers be allowed to submit a stablecoin-specific appendix or schedule.

Some commenters stated that the OCC should allow other executives, besides the Chief Financial Officer or the individual performing the equivalent function, to provide the quarterly report attestation.  The commenters also recommended that the OCC allow a subset of the board of directors and senior management, as opposed to all members of the board of directors and senior management, to attest to the correctness of quarterly reports.  The OCC believes that the Chief Financial Officer, or the individual performing the equivalent function, is the correct member of senior management to be accountable for providing an attestation to the accuracy of quarterly reports.  A single accountable member of senior management will help ensure that a member of senior management has ownership of a permitted payment stablecoin issuer’s financial reporting function.  Similarly, the OCC believes that requiring all members of the board of directors and senior management to attest to the correctness of quarterly reports will help ensure that the board of directors and senior management are engaged in the oversight of the permitted payment stablecoin issuer’s financial reporting function.

Upon consideration of the comments received, the OCC has elected to adopt the quarterly reporting provision as proposed with new subdivisions and other technical edits.  Final § 15.14(i)(1) requires a quarterly report on the financial condition, final § 15.14(i)(2) requires a declaration that the report is true and correct, and final § 15.14(i)(3) requires certain signatures of directors and senior management.  The technical edits involve the addition of “and” to final § 15.14(i)(1) for clarity and the addition of commas in final § 15.14(i)(3) for clarity.  In the interest of promoting transparency, the OCC has determined that each permitted payment stablecoin issuer must submit a quarterly report of condition.  The agency has adopted this approach because it establishes a uniform requirement across all permitted payment stablecoin issuers and will minimize public confusion about where to find quarterly reports of condition for permitted payment stablecoin issuers.  If some permitted payment stablecoin issuers were allowed to attach quarterly reports of condition to Call Reports, the public could find it challenging to locate stablecoin-specific quarterly reporting forms if it is not widely known or understood that a permitted payment stablecoin issuer is a subsidiary of an institution that is a Call Report filer.  Therefore, the OCC has elected to adopt a uniform quarterly reporting requirement for all permitted payment stablecoin issuers.

One commenter stated that large and complex permitted payment stablecoin issuers (e.g., those above $10 billion in payment stablecoin issuance or that meet the other criteria cited above) should be required to report at a much higher frequency than quarterly, similar to the prudential bank requirements for the largest banking organizations.  Under § 15.14(h) of the final rule, all permitted payment stablecoin issuers will be required to provide weekly confidential reporting to the OCC.

One commenter stated that the quarterly reporting requirement in proposed § 15.14(i) should be tailored to ensure proportionality across the rulemaking and consistency across prudential regulators, to avoid unnecessary duplication and be consistent with a risk-based supervisory approach.

One commenter recommended making quarterly reporting data publicly available as the reports are likely to contain material facts that are pertinent to stablecoin holders and other data users.  Similar to the publication of Call Reports, the OCC intends to publish the quarterly reporting forms for OCC-supervised permitted payment stablecoin issuers.

Other Supervisory Reports (§ 15.14(j))

Proposed § 15.14(j) addressed section 6(a)(2) of the GENIUS Act (12 U.S.C. 5905(a)(2)) and would have required each permitted payment stablecoin issuer subject to the requirements of section 6(a)(1) of the Act to, upon request, submit to the OCC a report on: (1) the financial condition of the permitted payment stablecoin issuer; (2) the systems of the permitted payment stablecoin issuer for monitoring and controlling financial and operating risks; (3) compliance by the permitted payment stablecoin issuer (and any subsidiary thereof) with the GENIUS Act and proposed part 15; and (4) compliance of the permitted payment stablecoin issuer with the Bank Secrecy Act and with laws authorizing the imposition of sanctions and implemented by the Secretary of the Treasury (12 U.S.C. 5905(a)(2)).

In an effort to clarify the GENIUS Act’s requirements, the OCC proposed in § 15.14(j)(4) to expand the requirement in section 6(a)(2)(D) of the GENIUS Act (12 U.S.C. 5905(a)(2)(D)) that Federal qualified nonbank payment stablecoin issuers produce reports of compliance with the requirements of the Bank Secrecy Act and with laws authorizing the imposition of sanctions and implemented by the Secretary of the Treasury to all permitted payment stablecoin issuers.

The proposal also requested feedback on this expanded approach and whether the OCC should apply this requirement to all permitted payment stablecoin issuers.  One commenter stated that the requirement should apply to all OCC-supervised permitted payment stablecoin issuers.  The commenter stated that BSA and sanctions risks are not meaningfully reduced by charter type. The commenter also claimed that stablecoin-specific AML and CFT expectations are being applied internationally across issuer categories rather than solely to nonbanks.  The commenter further recommended providing uniform substantive coverage with proportional, non-duplicative collection of information—i.e., if a bank subsidiary’s parent already provides equivalent information through existing supervisory channels, the OCC can rely on that information to avoid duplicate reporting.  Another commenter stated that the requirements to provide reports on compliance with the BSA should not be required for permitted payment stablecoin issuers that are already subject to the BSA, including national banks (whether insured or otherwise) and their subsidiaries.

After careful consideration of the comments, the OCC has elected to revise § 15.14(j) in the final rule to better reflect section 6(a)(2) of the GENIUS Act (12 U.S.C. 5905(a)(2)).  As a result, final § 15.14(j)(4) will apply only to Federal qualified nonbank payment stablecoin issuers10 in the final rule, codifying the reporting requirements as provided for in the GENIUS Act and not expanding the requirement to all permitted payment stablecoin issuers.  The OCC notes that it may nevertheless obtain information relating to the compliance of a permitted payment stablecoin issuer with the requirements of the Bank Secrecy Act and laws authorizing the imposition of sanctions as part of ongoing supervision.

Application Process (§ 15.30)

One commenter requested that the OCC provide, for notice and comment, application forms that market participants would have to submit to the OCC to become permitted payment stablecoin issuers under proposed § 15.30(b)(1)(i).  The commenter also requested these forms outline substantive information requirements and approval conditions which would not be subject to change absent additional opportunity for notice and comment.  Pursuant to the Paperwork Reduction Act of 1995, the OCC is soliciting comment on § 15.30 information collections that will be contained in the licensing forms and required applications (91 FR 47032 and 91 FR 68229).

Several commenters suggested the types of information the OCC should require to be included in applications made pursuant to § 15.30.  Some commenters supported traditional data inputs such as unique identification numbers to optimize application tracking and business model descriptions including incentive structures associated with stablecoin use to ensure the GENIUS Act's prohibition on yield is observed.  One of the commenters requested clarification on what information the OCC would require to evaluate management competence and experience in the absence of direct regulatory stablecoin experience.  The same commenter also requested clarification on what information the OCC will require with respect to in-kind capital contributions.  Another commenter suggested that applicants seeking approval or waiver under § 15.30 provide a narrative description detailing stablecoin issuance and settlement, sustained operational capacity, governance and control structures, recovery procedures, sequencing dependencies, and material third-party operational relationships.  A third commenter proposed that applications be prepared in a digital, machine-readable format to generate useful regulatory data and lower costs.  Proposed § 15.30(c), consistent with section 5(c) of the GENIUS Act (12 U.S.C. 5904(c)), enumerated the criteria, including expectations for officers, directors, and principal shareholders, pursuant to which applications will be evaluated.  Proposed subpart E, consistent with section 4(a)(4) of the GENIUS Act (12 U.S.C. 5903(a)(4)), discusses capital requirements.  As discussed in greater detail below, the final rule adds as a review criterion, under § 15.30(d)(5), the ability of the applicant to conduct its proposed activities in a safe and sound manner, including whether the applicant's proposed structure adequately addresses run risks and adequately ensures the ability to redeem payment stablecoins.  The required application information will be consistent with the enumerated criteria, and information submitted by an applicant should be sufficient to allow the OCC to render a decision on whether the applicant satisfies the enumerated criteria.  As the OCC gains additional experience and data from licensing permitted payment stablecoin issuers, it will consider updating required application information as well as the format in which it is submitted.

Registration of Foreign Payment Stablecoin Issuers (§ 15.32)

One commenter was generally supportive of the registration provision in § 15.32.  One commenter suggested that the OCC should publish a clear checklist specifying the documentation necessary for a foreign registration application to be deemed complete.  Pursuant to the Paperwork Reduction Act of 1995, the OCC is soliciting comment on information that will be collected in the forms required under subpart D (91 FR 47032 and 91 FR 68229).

Efficiency and Burden Reduction (§§ 15.14(n) and 15.14(o))

Proposed § 15.14(n) provided that, in supervising and examining a permitted payment stablecoin issuer, the OCC will use existing reports and other supervisory information to the fullest extent possible.  The OCC stated that this subsection was intended to reduce unnecessary burden by allowing the OCC to leverage information already available through existing reporting or supervisory channels.

Proposed § 15.14(o) provided that the OCC will, to the fullest extent possible, avoid duplication of examination activities, reporting requirements, and requests for information.  The OCC stated that this subsection reflects an express effort to minimize redundant supervisory demands while preserving the OCC’s ability to obtain information needed for effective oversight.

The OCC received a number of comments related to burden reduction and the avoidance of duplication.  One commenter recommended that the agency explicitly recognize internal audit work product as a category of existing supervisory information that examiners may rely on where such work is relevant, current, and performed in accordance with recognized professional standards.  The commenter claimed that this approach would reduce issuer compliance burden, improve supervisory efficiency, and create positive incentives for investment in high-quality internal audit programs.

Two commenters recommended that the OCC allow a permitted payment stablecoin issuer that is a subsidiary of an insured depository institution to leverage its parent’s enterprise-wide risk management infrastructure, including risk appetite statements and third-party risk management programs, where appropriate, to satisfy risk-management and supervisory requirements.  One of the commenters further recommended that the OCC include guidance to this effect in its commentary to the final rule and the Comptroller’s Handbook.  The OCC confirms that a permitted payment stablecoin issuer may leverage enterprise-wide infrastructure, provided that the permitted payment stablecoin issuer does so in compliance with the requirements of part 15.

Another commenter encouraged the OCC to develop centralized and standardized reporting mechanisms—such as a secure reporting portal—that are aligned with existing bank reporting systems and service provider capabilities.  The commenter stated that new reporting requirements applicable to community banks should be limited, targeted, and designed to leverage data already maintained in the ordinary course of business.  The commenter also claimed that stablecoin-related risks can be effectively evaluated by incorporating them into established examination modules.  The commenter stated that stablecoin-related audit and reporting obligations for bank-affiliated issuers should be appropriately integrated into existing supervisory frameworks rather than imposed through separate or duplicative regimes.  The OCC will continue to consider means of updating its reporting mechanisms, but no change in the text of the regulation is necessary at this time to address the comment.

Another commenter stated that the reporting requirements across weekly, monthly, and quarterly intervals should build on one another rather than requiring duplicative reporting.  Monthly reports should, to the extent possible, draw from weekly reports, and likewise quarterly reports should draw from monthly reports.  The commenter claimed that such an approach can reduce operational burden while preserving the OCC’s and the public’s ability to assess risk over time.  The commenter also stated that to best minimize the duplication of reports, the OCC’s focus should be on mitigating risk while encouraging innovation.  The commenter stated that requiring duplicative reports does not provide additional risk-mitigation benefits while diverting resources and creating unnecessary burden.

Another commenter stated that the OCC can best minimize duplication by implementing a single annual audit package that satisfies overlapping requirements across § 15.14(l), monthly reserve examination outputs, and related financial-condition reporting fields, rather than requiring multiple separate submissions of the same underlying data.  The commenter stated that the goal should be to collect the necessary information once, in a standardized format, and reuse it across the prudential framework where possible.  For issuers, or their parents, that are already subject to Exchange Act reporting or meet the Act’s $50 billion public accounting threshold, the OCC should not require additional duplicative reporting beyond what is necessary to capture stablecoin-specific fields that existing filings do not address.

Pursuant to its statutory obligations, the OCC will pursue supervisory policies that minimize duplication and maximize efficiency.  The OCC notes, however, that the reports applicable to permitted payment stablecoin issuers serve distinct purposes.  For example, the confidential weekly reporting is intended to provide detailed information that would be unnecessary to include in the quarterly or monthly reports.  The monthly and quarterly reports are intended to provide information to the public and the OCC that may be stale or less valuable if received only on an annual basis.

After careful consideration of the comments, the OCC has implemented § 15.14(n) and § 15.14(o) as proposed.  As described above, the OCC is committed to pursuing supervisory policies that minimize duplication and maximize efficiency.

For a more detailed discussion of the comments received regarding the reporting, recordkeeping, or disclosure requirements found in the rule, please see the SUPPLEMENTARY INFORMATION section of the final rule document (91 FR 67000).

9. Payment to respondents:

None.

10. Assurance of confidentiality:

None.

11. Justification for questions of a sensitive nature:

There are no questions of a sensitive nature.  

12. Burden estimate:


Estimated Number of Respondents
Estimated Frequency of Response
Estimated Average Hours per Response
Estimated Annual Burden hours
Initial Set-up
Reporting Burden
Section 15.10(c)(5)(iii)(B)
39
1
4
156
Section 15.11(a)(2)
39
1
4
156
Section 15.11(e)(2)
39
1
1
39
Section 15.11(e) Table 
39
1
1
39
Section 15.11(g)(1)
39
1
1
39
Section 15.11(g)(4)(i)
39
1
4
156
Section 15.12(d)(1)
1
1
0.5
0.5
Section 15.12(d)(2)
1
1
0.5
0.5
Section 15.13(a)(3)
39
1
160
6,240
Section 15.13(a)(9)(i)
39
1
160
6,240
Section 15.13(a)(9)(ii)
39
1
160
6,240
Section 15.13(a)(9)(iii)
39
1
160
6,240
Section 15.13(a)(10)(iii)
1
1
1
1
Section 15.13(b)(7)(i)
39
1
4
156
Section 15.13(b)(7)(ii)
39
1
4
156
Section 15.14(h)
39
1
16
624
Section 15.14(i)
39
1
80
3,120
Section 15.14(j)
39
1
16
624
Section 15.14(k)
39
1
80
3,120
Section 15.14(l)(1)
1
1
40
40
Section 15.14(l)(2)(ii)
1
1
480
480
Section 15.14(l)(2)(iii)
1
1
8
8
Section 15.14(m)
39
1
2
78
Section 15.15(b)(2)
1
1
4
4
Section 15.15(b)(3)
1
1
40
40
Section 15.15(b)(4)
1
1
8
8
Section 15.15(d)(1)
1
1
8
8
Section 15.30(a)(1)
25
1
1
25
Section 15.30(a)(2)
14
1
1
14
Section 15.30(b)11
25
1
40
1,000
Section 15.30(f)(1)
14
1
1
14
Section 15.30(f)(3)
1
1
40
40
Section 15.30(g)(1)
25
1
8
200
Section 15.30(g)(2)
14
1
8
112
Section 15.31(a)(3)(ii)(D)(1)
1
1
40
40
Section 15.31(b)(2)(i)
1
1
80
80
Section 15.31(b)(2)(ii)
1
1
1
1
Section 15.32(a)
1
1
1
1
Section 15.32(b)
1
1
80
80
Section 15.32(e)(3)(i)
1
1
1
1
Section 15.32(e)(3)(ii)
1
1
1
1
Section 15.32(e)(3)(ii) Table
1
1
10
10
Section 15.32(e)(3)(iii)
1
1
1
1
Section 15.32(g)(2)
1
1
1
1
Section 15.32(g)(5)
1
1
1
1
Section 15.40(c)(5)
39
1
1
39
Section 15.41(b)(1)(iii)
39
1
1
39
Section 15.41(c)(1)(i)
39
1
1
39
Section 15.41(c)(1)(ii)
39
1
1
39
Section 15.41(d)(1)
1
1
1
1
Section 15.41(d)(2)
1
1
2
2
Section 15.41(d)(4)
1
1
1
1
Section 15.42(c)(2)(i)
39
1
40
1,560
Section 15.42(c)(4)
39
1
40
1,560
Total Reporting Burden                                                                                                                                    38,915

Recordkeeping Burden
Section 15.11(a)(1)
39
1
40
1,560
Section 15.11(f)(1)
39
1
8
312
Section 15.11(f)(2)
39
1
8
312
Section 15.12(c)
39
1
8
312
Section 15.13(a)(1)
39
1
80
3,120
Section 15.13(a)(2)
39
1
80
3,120
Section 15.13(a)(5)
39
1
80
3,120
Section 15.13(a)(6)(i)(D)
39
1
8
312
Section 15.13(a)(10)(ii)(D)
1
1
40
40
Section 15.13(b)(1), (2), (3), (4), (6), and (8)
39
1
160
6,240
Section 15.13(b)(5)
39
1
80
3,120
Section 15.14(f)
39
1
40
1,560
Section 15.14(g)
39
1
40
1,560
Section 15.14(l)(1)
1
1
1
1
Section 15.15(b)(1)(i) and (ii)
1
1
160
160
Section 15.15(b)(4)(ii)
1
1
1
1
Section 15.21(b)(1)
21
1
8
168
Section 15.21(b)(2)(i)
1
1
1
1
Section 15.22(c)
1
1
1
1
Section 15.41(a)(2)(ii)
39
1
40
1,560
Section 15.41(c)(5)
39
1
40
1,560
Total Recordkeeping Burden                                                                                                                           28,140

Disclosure Burden
Section 15.11(e)(1)
39
1
40
1,560
Section 15.12(b)
39
1
0.5
19.5
Section 15.12(e)
39
1
16
624
Section 15.14(l)
1
1
4
4
Section 15.14(l)(2)(i)
1
1
16
16
Section 15.22(b)
1
1
1
1
Section 15.32(e)(1) and (2)
1
1
8
8
Total Disclosure Burden                                                                                                                             2,233 (rounded)

Total Initial Set-up                                                                                                                                      69,288 


Estimated Number of Respondents
Estimated Frequency of Response
Estimated Average Hours per Response
Estimated Annual Burden hours
Ongoing Compliance
Reporting Burden
Section 15.10(c)(5)(iii)(B)
39
1
1
39
Section 15.11(a)(2)
39
1
16
624
Section 15.11(e)(2)
39
12
2
936
Section 15.11(e) Table 
39
12
2
936
Section 15.11(g)(1)
39
1
1
39
Section 15.11(g)(4)(i)
39
1
8
312
Section 15.12(d)(1)
1
1
1
1
Section 15.12(d)(2)
1
1
1
1
Section 15.13(a)(3)
39
1
1
39
Section 15.13(a)(9)(i)
39
1
1
39
Section 15.13(a)(9)(ii)
39
1
1
39
Section 15.13(a)(9)(iii)
39
1
1
39
Section 15.13(a)(10)(iii)
1
1
1
1
Section 15.13(b)(7)(i)
39
1
1
39
Section 15.13(b)(7)(ii)
39
1
1
39
Section 15.14(h)
39
52
2
4,056
Section 15.14(i)
39
4
16
2,496
Section 15.14(j)
39
1
40
1,560
Section 15.14(k)
39
1
8
312
Section 15.14(l)(1)
1
1
4
4
Section 15.14(l)(2)(ii)
1
1
40
40
Section 15.14(l)(2)(iii)
1
1
16
16
Section 15.14(m)
39
1
2
78
Section 15.15(b)(2)
1
1
1
1
Section 15.15(b)(3)
1
1
1
1
Section 15.15(b)(4)
1
1
1
1
Section 15.15(d)(1)
1
1
1
1
Section 15.30(a)(1)
25
1
1
25
Section 15.30(a)(2)
14
1
1
14
Section 15.30(b)12
25
1
1
25
Section 15.30(f)(1)
14
1
1
14
Section 15.30(f)(3)
1
1
1
1
Section 15.30(g)(1)
25
1
1
25
Section 15.30(g)(2)
14
1
1
14
Section 15.31(a)(3)(ii)(D)(1)
1
1
1
1
Section 15.31(b)(2)(i)
1
1
80
80
Section 15.31(b)(2)(ii)
1
1
1
1
Section 15.32(a)
1
1
1
1
Section 15.32(b)
1
1
1
1
Section 15.32(e)(3)(i)
1
12
1
12
Section 15.32(e)(3)(ii)
1
12
1
12
Section 15.32(e)(3)(ii) Table
1
12
2
24
Section 15.32(e)(3)(iii)
1
1
1
1
Section 15.32(g)(2)
1
1
1
1
Section 15.32(g)(5)
1
1
1
1
Section 15.40(c)(5)
39
1
1
39
Section 15.41(b)(1)(iii)
39
1
1
39
Section 15.41(c)(1)(i)
39
4
0.5
78
Section 15.41(c)(1)(ii)
39
4
0.5
78
Section 15.41(d)(1)
1
1
1
1
Section 15.41(d)(2)
1
1
1
1
Section 15.41(d)(4)
1
1
1
1
Section 15.42(c)(2)(i)
39
1
1
39
Section 15.42(c)(4)
39
1
1
39
Total Reporting Burden                                                                                                                                   12,257

Recordkeeping Burden
Section 15.11(a)(1)
39
12
4
1,872
Section 15.11(f)(1)
39
12
2
936
Section 15.11(f)(2)
39
12
0.25
117
Section 15.12(c)
39
1
4
156
Section 15.13(a)(1)
39
1
1
39
Section 15.13(a)(2)
39
1
1
39
Section 15.13(a)(5)
39
1
1
39
Section 15.13(a)(6)(i)(D)
39
1
1
39
Section 15.13(a)(10)(ii)(D)
1
1
1
1
Section 15.13(b)(1), (2), (3), (4), (6), and (8)
39
1
1
39
Section 15.13(b)(5)
39
1
1
39
Section 15.14(f)
39
1
8
312
Section 15.14(g)
39
1
1
39
Section 15.14(l)(1)
1
1
1
1
Section 15.15(b)(1)(i) and (ii)
1
1
1
1
Section 15.15(b)(4)(ii)
1
1
1
1
Section 15.21(b)(1)
21
1
1
21
Section 15.21(b)(2)(i)
1
1
1
1
Section 15.22(c)
1
1
1
1
Section 15.41(a)(2)(ii)
39
1
1
39
Section 15.41(c)(5)
39
1
1
39
Total Recordkeeping Burden                                                                                                                            3,771

Disclosure Burden
Section 15.11(e)(1)
39
12
8
3,744
Section 15.12(b)
39
1
0.5
19.5
Section 15.12(e)
39
1
1
39
Section 15.14(l)
1
1
8
8
Section 15.14(2)(i)
1
1
8
8
Section 15.22(b)
1
1
1
1
Section 15.32(e)(1) and (2)
1
1
1
1
Total Disclosure Burden                                                                                                                                  3,821 (rounded)

Total Ongoing Compliance                                                                                                                             19,849

Grand Total                                                                                                                                                      89,137 

Total estimated annual burden hours: 89,137 (69,288 hours for initial setup and 19,849 hours for ongoing compliance).

Cost of Hour Burden:

89,137 hours x $ 158.73 = $ 14,148,716.01

To estimate wages the OCC reviewed May 2025 data for wages (by industry and occupation) from the U.S. Bureau of Labor Statistics (BLS) for credit intermediation and related activities (NAICS 5220A1).  To estimate compensation costs associated with the rule, the OCC uses $158.73 per hour, which is based on the average of the 90th percentile for six occupations adjusted for inflation (3.4 percent as of Q1 2026), plus an additional 35.3 percent for benefits (based on the percent of total compensation allocated to benefits as of Q4 2025 for NAICS 522: credit intermediation and related activities).credit intermediation and related activities).
                                                                                                    
13. Estimate of the total annualized cost to respondents:

None.

14. Estimate of annualized cost to the federal government:

None.

15. Changes in burden:

	This is the first time this data is being collected.  There are no program changes or adjustments made to the information collection request at the time of submission.

16. Information regarding collections whose results are planned to be published for statistical purposes:

The OCC has no plans to publish the information for statistical purposes.

17. Display of expiration date:

Not applicable.  

18. Exceptions to certification statement in Item 19 of OMB Form 83-I:

None.

B.  Collections of information employing statistical methods

Not applicable.