The OCC's stablecoin issuer reporting playbook may not stay federal for long

Key takeaways

• The Office of the Comptroller of the Currency’s (OCC) recently proposed reporting forms represent a significant expansion of supervisory data collection for stablecoin issuers, with new requirements including daily-frequency data on reserves, redemption, concentration, and secondary-market pricing—submitted weekly. Form PS-02 requires quarterly financial condition reporting with CFO and board attestation.
• The OCC reporting requirement may have broader implications for state regulation because the GENIUS Act requires state regulatory regimes to be substantially equivalent to the federal framework, and Treasury’s proposed state-equivalency rule defines that framework to include OCC regulations—potentially requiring states to adopt comparable reporting obligations, even if not the OCC’s specific form fields, in order to remain consistent with federal requirements in all substantive respects.
• The OCC is simultaneously building a chartering on-ramp for digital-native firms. Recent trust bank approvals and the clarification that national trust banks may conduct nonfiduciary activities signal a coherent federal pathway for stablecoin entrants.
• The OCC's reporting package applies equally to registered foreign payment stablecoin issuers, creating cross-border pressure toward convergence in supervisory data standards. The OCC has shown its hand on stablecoin supervision, and the reporting requirements its proposed forms envision are greater than many expected. For stablecoin issuers and their advisers, the reporting and supervision architecture for stablecoin oversight is taking shape at the OCC, and this framework, if finalized, will likely function as the de facto national baseline for stablecoin oversight regardless of whether an issuer holds a federal or state license.

  Developing federal framework

  On March 2, 2026, the OCC issued its comprehensive GENIUS Act implementation proposed rule (91 FR 10202), and on June 11, 2026, it followed with a proposed reporting form notice and request for comment that would require OCC-supervised permitted payment stablecoin issuers (PPSIs) and registered foreign payment stablecoin issuers (FPSIs) to submit weekly and quarterly data directly to the agency (91 FR 35795). In addition, Treasury issued its own separate April 3, 2026, proposal that would judge state supervisory regimes partly by whether they are "substantially similar" to the federal framework, which Treasury expressly defines to include the GENIUS Act and the core regulatory framework set up by the OCC and other federal agencies to implement the statute (91 FR 16844).

  Timing and reporting requirements

  The OCC's GENIUS Act proposed rule was published on March 2, 2026 (comments closed May 1), and Treasury's state-similarity proposal was published on April 3, 2026 (comments closed June 2). The final rules are expected later this year. The OCC's June 11 notice and request for comment on the new reporting forms remains open for a 60-day comment period that will close on August 11, 2026.

  The OCC as central federal actor

  The OCC's proposed rule confirms the agency's primacy within the GENIUS Act framework. Its authority extends not only to subsidiaries of national banks and federal savings associations but also to federal qualified nonbank PPSIs, certain state-qualified issuers (above the $10 billion threshold), and foreign payment stablecoin issuers seeking U.S. market access. The Federal Deposit Insurance Corporation (FDIC), Federal Reserve, and National Credit Union Administration (NCUA) are also relevant within this framework, but only where the issuer sits inside an institution they already supervise. In practice, the OCC will be setting the tone for PPSI supervision across the industry, especially for fintech-native and nonbank entrants who have no pre-existing federal banking relationship.

  OCC Form PS-01: Weekly supervisory reporting

  The OCC proposes Form PS-01 as a weekly report submitted separately for each payment stablecoin an issuer sponsors. It collects daily data rolled into weekly submissions across eight schedules covering issuance and redemption, reserve assets, cash balances, Treasury securities, reverse repos, money market funds, and other instruments. Among the required data points are the following: outstanding wallet concentrations, gross daily buy/sell volume, exchange-level trading volume, issuance and redemption by blockchain, restricted or time-locked coins, peg deviation and bid/ask spread metrics, redemption timing, and dollar amounts of redemptions outstanding beyond 48 hours. On the reserve side, the form captures the following: fair value, amortized cost, daily minimum and maximum balances, weighted average maturity and life, unrealized gains and losses, effective interest rate, interest income allocation, and tokenized reserve portions. Weekly reports are due each Wednesday by 5:00 p.m. ET through OCC BankNet. This reporting represents near real-time supervisory oversight for liquidity, run risk, market functioning, and reserve composition, that is closer in philosophy to the continuous monitoring the OCC applies to systemically important banks than to anything previously required of a payments company. The OCC views PPSIs as warranting a level of supervisory intensity that far exceeds anything historically applied to money transmitters or payments companies. Issuers should begin evaluating now whether their internal data infrastructure can support this volume of reporting and the reporting cadence.

  OCC Form PS-02: Quarterly condition reporting with teeth

  The quarterly complement Form PS-02 mirrors the Consolidated Reports of Condition and Income (Call Reports) filed by national banks and federal savings associations but is streamlined substantially in light of the comparatively simple business model of a PPSI. It requires GAAP-based income, balance sheet, off-balance-sheet, and capital data across five schedules, due within 30 calendar days of quarter-end. Critically, it must be signed by the CFO (or equivalent) and attested to by directors and senior management, thereby embedding board-level accountability for the data, not merely data collection. For firms that lack a CFO, independent board oversight of financial reporting, or the internal control frameworks that would give a senior officer confidence in signing such an attestation, meeting this requirement may require hiring new executives, restructuring the board, and implementing formal internal controls. 

  State-similarity pressures

  If Treasury finalizes its state equivalency proposed rule in anything close to current form, states supervising issuers with no more than $10 billion in outstanding issuance will need to demonstrate comparable supervisory results, not simply comparable statutory language. Treasury proposes to group the core prudential requirements of the GENIUS Act (found in Section 4(a), which covers reserves, redemption, rehypothecation, capital, liquidity, risk management, Bank Secrecy Act sanctions compliance, and permissible activities) into two categories: "uniform requirements" that must be consistent with the federal framework "in all substantive respects," and "state-calibrated requirements" (such as capital and liquidity standards) where states retain more discretion but must still produce "regulatory outcomes that are at least as stringent and protective as the Federal regulatory framework." The practical implication is clear: Once the OCC operationalizes supervision through weekly and quarterly returns, state regulators will likely face pressure to match that granularity or risk failing the substantially-similar standard on which their continued authority to supervise stablecoin issuers depends.

  More importantly, the underlying proposed OCC implementing regulation at 12 C.F.R. 15.14(h) and (i) 91 FR 10202—which mandates weekly and quarterly reporting—will fall within Treasury’s proposed equivalency definition of the “Federal regulatory framework” at § 1521.1(c). That means that under these proposed frameworks of both Treasury and the OCC, states will almost certainly need to require reporting at comparable frequency. But the specific form fields are established through this report form PRA information collection process, not the proposed implementing regulation itself, which gives states a plausible argument for flexibility on the precise weekly data collection, so long as they can demonstrate equivalent supervisory visibility through alternative means.

  That said, the practical force of this distinction should not be overstated. Even if states are not legally required to mirror the OCC's exact form fields, the Stablecoin Certification Review Committee will still need to determine that a state's regime "meets or exceeds" the standards described in Section 4(a) of the GENIUS Act. A state that requires weekly reporting but collects materially less data than the OCC may struggle to demonstrate that its supervisory outcomes are "at least as stringent and protective as the Federal regulatory framework." The regulation/form distinction gives states a legal hook for differentiation, but the outcomes-based test may narrow that flexibility in practice.

  An open procedural question: Could the final rules close the gap?

  The regulation/form distinction described above rests on the current structure of the OCC's proposed rule, which mandates reporting frequency in its regulation but leaves the specific data fields to the PRA information collection. That structure could change at the final rule stage in two ways.

  First, the OCC itself could incorporate specific data requirements directly into the final regulation at 12 CFR Part 15 by specifying minimum categories of data (reserve composition, concentration, redemption metrics, secondary-market pricing, etc.) that must be reported weekly, even if the precise field-by-field formatting remains in the PRA forms. If the OCC takes that step, the specific data categories would become part of the regulation and would be captured by Treasury's § 1521.1(c) definition and significantly narrow the "form or procedure" argument available to states. The OCC's proposed rule already invited comment on the reporting forms and their relationship to the regulation, which provides adequate notice for this kind of refinement at the final rule stage.

  Second, Treasury might revise its final state equivalency rule to expressly incorporate the OCC's reporting framework as a condition of certification or cross-reference the OCC's forms in a way that effectively requires state compliance with the data model. Whether Treasury can do so without a supplemental notice-and-comment rulemaking is less clear. Treasury's current proposal does not directly address reporting frequency or form requirements; it focuses on broad-based principles for substantive standards. If the final rule were to add reporting-specific conditions not present in the April 3 proposal, that could be viewed as a material change that interested parties did not have an adequate opportunity to comment on under the Administrative Procedure Act.

  Both possibilities underscore the same point: The current flexibility on data fields may be temporary. Market participants and state regulators should monitor both final rules closely and, at minimum, use the OCC's open comment period on the report form notice to address whether specific data categories should be elevated from the PRA forms into the regulation itself.

  Current state processes may need to be upgraded

  Today, state money transmitter supervision operates primarily through the Nationwide Multistate Licensing System, quarterly money services businesses (MSB) call reports, coordinated examinations, and Money Transmission Modernization Act (MTMA) prudential standards. The Conference of State Bank Supervisors (CSBS) reports that 31 states have enacted the MTMA in full or in part and that firms licensed in at least one MTMA state account for 99% of reported money transmission activity. That is significant infrastructure, but it is not comparable to the OCC’s proposed coin-by-coin weekly reserve and redemption reporting.

  New York is the clearest exception and preview. Since 2022, New York State Department of Financial Services (NYDFS) has imposed stablecoin-specific requirements on redeemability, reserve backing, and attestations. On June 9, 2026, NYDFS proposed a new regulation expressly aimed at harmonizing with GENIUS Act requirements, adding custodian concentration limits and formal risk management programs covering internal controls, information security, internal audit, and service provider arrangements. New York is already moving from principle-based supervision toward the explicit prudential-and-reporting architecture Treasury is likely to expect. Other states should take note.

  For other states, the challenge is how much they must upgrade their reporting stack. A regime built around quarterly MSB reports, annual financial statements, and periodic examinations may be hard to defend as "substantially similar" when the OCC collects weekly issuer-specific reserve, redemption, market, and concentration data. The practical consequence is convergence by necessity as those states that want to remain relevant under GENIUS will have to transform themselves from classic money-transmitter supervisors into something closer to prudential supervisors of narrow-payment institutions with the reporting infrastructure to match. For issuers currently licensed under state regimes, this means the regulatory environment will change beneath their feet regardless of whether they ever seek a federal charter.

  The federal chartering path as an alternative

  That convergence sharpens the appeal of the federal route. In February 2026, the OCC finalized a rule clarifying that national trust banks may engage in nonfiduciary activities in addition to fiduciary ones, reducing the argument that such banks must operate as pure fiduciary silos. The same period saw the OCC grant preliminary conditional approval to several de novo trust bank charters tied to stablecoin activity. The OCC is building not only a supervisory rulebook for PPSIs but also a chartering on-ramp for digital-native firms that want to come fully inside a national banking framework and gain the preemption, uniformity, and credibility benefits that come with an OCC charter.

  Preemption reinforces this dynamic. The GENIUS Act generally preempts conflicting state requirements while preserving a continued state role for smaller issuers under certified substantially similar regimes. The federal route carries heavier direct supervision and intensive recurring reporting but also offers greater uniformity, legal certainty, and examination credibility. The state route may remain attractive for smaller issuers, particularly in New York or other states that invest heavily in upgrading their frameworks, but only if those states can convince Treasury that their supervisory machinery is genuinely equivalent in substance and granularity to the OCC’s framework.

  Cross-border implications

  The OCC's reporting package expressly applies to registered foreign issuers, meaning foreign firms seeking U.S. market access will face the same weekly and quarterly reporting as domestic issuers. That creates powerful spillover pressure abroad: Foreign regulators will face a choice between moving toward comparable reserve and governance reporting standards or watching their domestic issuers get locked out of U.S. dollar stablecoin markets. NYDFS's June 2026 memorandum of understanding with the European Banking Authority (EBA) on stablecoin information exchange and supervision is an early sign of exactly this kind of cross-border supervisory convergence. We expect more bilateral and multilateral arrangements to follow.

  What U.S. and foreign issuers should do now

  For issuers (federal and state-licensed)

• Audit your internal data infrastructure against the OCC’s Form PS-01 field requirements, particularly daily reserve valuations, blockchain-level issuance tracking, wallet concentration monitoring, and secondary-market pricing feeds, and identify gaps.
• Assess whether your governance structure can support the Form PS-02 attestation requirements. If you lack a CFO or equivalent officer, or if your board has not historically been involved in regulatory data sign-off, begin planning for these changes.
• If you are currently state-licensed, model the impact of your state adopting OCC-comparable reporting. The regulatory cost of a state license may converge with the federal cost faster than expected, and this should be factored into your chartering strategy.
• File comments on the OCC's June 11 reporting notice before the 60-day window closes. Focus on specific data fields where the compliance burden is disproportionate to supervisory value, propose alternatives for the OCC to consider where possible, and address the interplay with Treasury’s substantial-similarity rule.

  For foreign issuers

• Foreign firms planning to register with the OCC for U.S. market access should begin building compliance infrastructure for both OCC Form PS-01 and PS-02 reporting now. The OCC has made clear that foreign issuers face the same reporting obligations as domestic PPSIs.
• Home-country regulators should evaluate whether their existing supervisory frameworks produce data that is interoperable with OCC requirements. The NYDFS-EBA memorandum of understanding offers a model for bilateral coordination, and early engagement with U.S. counterparts may smooth the path for mutual recognition or equivalence determinations.

Bottom line: The data reporting model is significant

One of the most consequential parts of the OCC's GENIUS Act implementation to date is the comprehensive weekly and quarterly reporting philosophy being proposed here. The proposed forms reflect an agency seeking continuous and ongoing visibility into issuance, redemption, reserve structure, concentration, and market functioning and not just backward-looking attestations. Because Treasury's definition of "Federal regulatory framework" will capture the OCC's reporting regulation (e.g., the weekly and quarterly obligations), the reporting cadence will not remain confined to federally supervised issuers for long. And while the specific form fields are technically a PRA information collection rather than a regulation, the outcomes-based test for “substantial similarity” will push states toward collecting comparable data regardless, because demonstrating equivalent supervisory visibility is very difficult without equivalent supervisory information. The net effect is that the OCC's reporting philosophy will become effectively binding on the entire ecosystem, even if states retain some flexibility on the precise data architecture.

For stablecoin issuers choosing among state, federal, trust-bank, and cross-border pathways, the real strategic question is no longer simply who the regulator is. It is which supervisory data reporting model they are prepared to live under and how quickly they can build the operational infrastructure to comply with it. The time to begin that assessment is now, not when the final rules are published.