On July 27, the OCC requested public comment on the forms entities would file to apply to issue payment stablecoins under the GENIUS Act, and the forms foreign issuers would file to register. They show how the licensing and registration process in the OCC’s March 2 proposed rule would work in practice: what an applicant sends in, what its executives have to submit, and what the OCC will use to decide. Comments are due September 25.

What the Collection Covers

Once the GENIUS Act takes effect, it will generally bar anyone other than a permitted payment stablecoin issuer (PPSI) from issuing payment stablecoins in the United States. It will also bar a foreign payment stablecoin issuer from offering, selling, or otherwise making a payment stablecoin available here unless it meets several conditions, including registration with the OCC. The proposed rule sets out the process for both. This notice covers the forms those entities would complete. Section references below are to the proposed rule.

What a PPSI Application Would Include

Section 15.30(b)(1) covers what an applicant files: an overview of the applicant, a detailed business plan, its proposed activities and their permissibility, and its reserve, redemption, and risk management policies. Each director, executive officer, and principal shareholder must also submit the information prescribed in the Interagency Biographical and Financial Report. The applicant must certify that nothing it files contains a material misrepresentation or omission.

Section 15.30(c) sets the factors the OCC would weigh:

  • Whether the applicant has the financial condition and resources to meet the requirements for issuing payment stablecoins.
  • Whether any officer or director has been convicted of a felony involving insider trading, embezzlement, cybercrime, money laundering, financing of terrorism, or financial fraud.
  • The competence, experience, and integrity of the officers, directors, and principal shareholders of the applicant, its subsidiaries, and its parent companies, including their compliance records and their ability to meet commitments or conditions the OCC imposed on this application or a prior one.
  • Whether the applicant’s redemption policy meets Section 15.12.

Foreign Issuer Registration

Section 15.32 handles foreign issuers. The application must include evidence that the Secretary of the Treasury has determined the issuer’s home regime is comparable to the GENIUS Act under section 18 of the Act, a certification that the issuer will give the OCC any information it needs to determine and enforce compliance, and the issuer’s consent to U.S. jurisdiction. The OCC would then weigh that determination, the financial and managerial resources of the issuer’s U.S. operations, and whether the issuer will provide adequate information. It would also weigh risks to U.S. financial stability, including timely redemption for U.S. customers, and illicit finance risks. The Treasury determination is the gate. Without it, there is no registration path.

Burden Estimate and Comment Topics

The OCC estimates 50 respondents annually, 50 total annual responses, and 6,250 total annual burden hours, which works out to 125 hours per application. It asks for comments on whether the collection is necessary, the accuracy of the burden estimate, ways to improve the information collected or reduce the burden, and estimates of startup and operating costs.

This is the 60-day notice. After it closes, the OCC will publish a second notice with a 30-day comment period and send the collection to the Office of Management and Budget (OMB) for review. Under the Paperwork Reduction Act, the OCC cannot require anyone to respond to a collection that does not display a valid OMB control number, and it is asking OMB for a new one here.

The OCC also has a second stablecoin collection pending. On June 12, it proposed weekly and quarterly reporting forms for permitted issuers and registered foreign issuers, with comments due August 11. The July collection covers the application. The June collection covers what an issuer files after approval or registration.

Our Take

The burden estimate is the number worth commenting on. A PPSI application looks like a new bank charter filing: a business plan, reserve and redemption policies, a risk management program, and biographical and financial reports for every director, executive officer, and principal shareholder. Against that list, 125 hours looks light. The estimate matters because commenting is the only way to tell the OCC what a complete application actually takes. The OCC has not issued a final rule, and the Act takes effect on the earlier of January 18, 2027, or 120 days after the primary federal payment stablecoin regulators issue final rules. Anyone planning to apply should start with the biographical and financial reports. Each one depends on an individual, not the company.