OCC Sets $5 Million Capital Floor for Federal Stablecoin Issuers, Plus 12-Month Operating Expense Buffer

According to the Office of the Comptroller of the Currency's proposed GENIUS Act regulations published in March 2026, newly approved federal payment stablecoin issuers would face a minimum initial capital requirement of $5 million during a de novo supervisory period lasting at least three years. The proposal also requires issuers to maintain liquid assets sufficient to cover 12 months of projected operating expenses, which for many startups could exceed the capital requirement itself. The OCC proposal, which closed for comments on May 1, represents a bank-style regulatory regime favoring applicants with established financial infrastructure, compliance staff and capital resources, making it more challenging for smaller fintech firms to enter the market independently.
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