On June 11, the Office of the Comptroller of the Currency (OCC) released a notice and request for comment on proposed weekly and quarterly reporting forms and instructions for permitted payment stablecoin issuers and foreign payment stablecoin issuers subject to the OCC’s supervision as part of a new information collection required under the Paperwork Reduction Act of 1996. The proposal marks a significant next step in the OCC’s implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), which was enacted on July 18, 2025, and establishes a comprehensive federal regulatory framework for payment stablecoin activities.

Background

On March 2, 2026, the OCC issued a proposed rule implementing the GENIUS Act’s requirements for entities under its jurisdiction (discussed here). The June 11 notice builds on that rulemaking by proposing specific weekly and quarterly reporting forms that permitted payment stablecoin issuers and foreign payment stablecoin issuers would be required to complete.

The OCC has emphasized that because the underlying proposed rule is not yet final, the reporting forms are subject to change (i.e., certain items may be modified or removed depending on the requirements of the final rule).

What the Proposed Reporting Forms Would Require

Weekly Reporting

The proposed weekly reporting form, which is confidential, is designed primarily to ensure compliance with the GENIUS Act’s reserve asset requirements. It would consist of eight schedules:

  • Schedule A — General: Information on the largest stablecoin holders by wallet address, exchanges facilitating trading, trading volume, and top counterparties data. The OCC intends to use this data to monitor primary and secondary market dynamics, including during periods of stress.
  • Schedule B — Issuance and Redemption: Data on stablecoin issuances and redemptions during the reporting period, along with secondary market price and trading activity. The OCC is considering thresholds to exclude trades that are too small or otherwise unrepresentative of current market conditions.
  • Schedule C — Reserve Assets: An aggregate view of the composition of reserve assets backing outstanding stablecoin issuance, including fair value and amortized cost by asset category, as well as the balance of tokenized assets.
  • Schedule D — Cash Balances: Information on cash held as reserve assets, including insured and uninsured deposits at U.S. and foreign depository institutions, Federal Reserve Bank balances, and repurchase agreement transactions.
  • Schedule E — U.S. Treasury Securities: CUSIP-level detail on U.S. Treasury securities held as reserve assets, including fair value, maturity, coupon and effective interest rates, custodian information, and data on any securities encumbered by repurchase agreements.
  • Schedule F — Reverse Repurchase Agreements: Information on reverse repurchase agreements held as reserve assets, including counterparty, cash lent, agreement type, agent, and collateral details such as collateral values, maturities, haircuts, weighted average maturity (WAM), and weighted average life (WAL).
  • Schedule G — Money Market Mutual Funds: Fund-level data on money market mutual funds held as reserve assets, including fund name, sponsor, CUSIP, net asset value, effective interest rate, WAM, WAL, and custodian information.
  • Schedule H — Other Instruments: A catch-all schedule for any reserve assets not covered by the other schedules, such as physical currency.

Quarterly Reporting

The proposed quarterly reporting forms are modeled on the Call Reports that national banks and federal savings associations are required to file. The OCC has stated that streamlined reporting is appropriate given the comparatively simple business model of a permitted payment stablecoin issuer. The quarterly forms would consist of five schedules:

  • Schedule A — Income Statement: Reserve asset income and expenses, other corporate income and expenses, and net income.
  • Schedule B — Balance Sheet: Reserve assets, other assets, liabilities, and capital, reported in accordance with U.S. GAAP.  The OCC generally expects reserve assets to be reported at fair value.
  • Schedule C — Off-Balance Sheet Items: Off-balance sheet assets and liabilities (excluding derivatives) and derivatives, including forward contracts, futures contracts, and exchange-traded and over-the-counter options contracts.
  • Schedule D — Capital and Operational Backstop: Capital elements and operational backstop information, including total expenses for the prior 12 months and the composition of operational backstop assets. Note that foreign payment stablecoin issuers would not be required to complete Schedule D.
  • Schedule E — Memorandum: Operational details, including issuer type, reserve asset income and expenses, other assets and liabilities, number of branded stablecoins issued, non-U.S. dollar assets and liabilities, stablecoin issuance and redemption data, burn data, blockchain information, redemption metrics, and custody activities.

The OCC has stated its intent to make quarterly report information publicly available to promote transparency regarding the financial condition of permitted payment stablecoin issuers on an ongoing basis.

Open Questions and Comment Opportunities

The OCC has identified several specific issues on which it is inviting public comment, including:

  • Whether both WAM and WAL measures are necessary, or whether one or neither should be retained.
  • The best technical format (XML or other) for submitting reported data.
  • How to handle “treasury stablecoins” (stablecoins minted but retained by the issuer) for purposes of issuance and redemption reporting.
  • Whether issuers subject to both the proposed forms and the Call Report should be required to complete both, or whether the new forms should replace the Call Report obligation.
  • Whether uninsured national trust banks that opt into the capital requirements of proposed 12 C.F.R. part 15, even if they do not issue stablecoins, should be required to complete the proposed quarterly forms.
  • Whether additional reporting items covering tokenized assets should be added to the weekly form.

The OCC estimates the total annual reporting burden at approximately 6,308 hours across all respondents (2,864 hours for initial setup and 3,444 hours for ongoing compliance) based on an estimated 29 permitted payment stablecoin issuers and one foreign payment stablecoin issuer.

Comments on the proposed forms must be submitted within 60 days of the notice’s publication in the Federal Register. After the close of the 60-day comment period, the OCC states that it intends to issue a second notice with a 30-day comment period.

Our Take

The OCC’s proposed reporting framework reflects the agency’s effort to build a rigorous but tailored supervisory infrastructure for stablecoin issuers operating under federal oversight. The weekly reserve asset reporting cadence is notably more frequent than traditional bank reporting cycles, underscoring the OCC’s view that stablecoin reserve transparency requires near-real-time visibility by the agency – particularly given the potential for rapid redemption runs during periods of market stress.