The GENIUS Act established which assets payment stablecoin issuers may hold in reserve. The OCC’s proposed implementing rules are where the more demanding work begins, imposing liquidity and diversification requirements that would go well beyond what most issuers currently disclose.
The asset categories themselves follow the Act’s specifications: Fed accounts, demand deposits, short dated Treasuries, overnight repos, government money market funds and tokenized versions of the above. But layered on top are concentration limits, liquidity floors and operational requirements that will require significant adjustment across much of the industry.
Issuers must keep at least 10% of reserves in Fed accounts or demand deposits, the true liquid floor. Within that 10%, no more than 50% may sit at any single institution, meaning the most liquid tier must be spread across at least two counterparties. A broader 30% must be accessible within five business days. No more than 40% of total reserves may be held at any single eligible financial institution, whether as deposits, custodied securities or bilateral repo exposures. The entire reserve portfolio must maintain a weighted average maturity, or WAM, of no more than 20 days. For issuers above $25 billion in outstanding issuance, at least 0.5% of reserves must be held as insured deposits, with a floor of $500 million.
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