Notice2026-21705
Agency Information Collection Activities: Proposed Information Collection; Submission for OMB Review; Reporting Forms and Instructions for Permitted Payment Stablecoin Issuers Subject to the Jurisdiction of the Office of the Comptroller of the Currency
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
October 23, 2026
Issuing agencies
Treasury DepartmentComptroller of the Currency
Abstract
The OCC, as part of its continuing effort to reduce paperwork and respondent burden, invites comment on a new information collection, as required by the Paperwork Reduction Act of 1995 (PRA). In accordance with the requirements of the PRA, the OCC may not conduct or sponsor, and the respondent is not required to respond to an information collection unless it displays a currently valid Office of Management and Budget (OMB) control number. The OCC is proposing a new information collection titled "Reporting Forms and Instructions for Permitted Payment Stablecoin Issuers Subject to the Jurisdiction of the Office of the Comptroller of the Currency," that would include weekly and quarterly reporting forms that must be completed by permitted payment stablecoin issuers and foreign payment stablecoin issuers. The OCC is seeking a new OMB control number for this information collection. The OCC also is giving notice that it has sent the collection to OMB for review.
Full Text
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<title>Federal Register, Volume 91 Issue 204 (Friday, October 23, 2026)</title>
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[Federal Register Volume 91, Number 204 (Friday, October 23, 2026)]
[Notices]
[Pages 66916-66939]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-21705]
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DEPARTMENT OF THE TREASURY
Office of the Comptroller of the Currency
Agency Information Collection Activities: Proposed Information
Collection; Submission for OMB Review; Reporting Forms and Instructions
for Permitted Payment Stablecoin Issuers Subject to the Jurisdiction of
the Office of the Comptroller of the Currency
AGENCY: Office of the Comptroller of the Currency (OCC), Treasury.
ACTION: Notice and request for comment.
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SUMMARY: The OCC, as part of its continuing effort to reduce paperwork
and respondent burden, invites comment on a new information collection,
as required by the Paperwork Reduction Act of 1995 (PRA). In accordance
with the requirements of the PRA, the OCC may not conduct or sponsor,
and the respondent is not required to respond to an information
collection unless it displays a currently valid Office of Management
and Budget (OMB) control number. The OCC is proposing a new information
collection titled ``Reporting Forms and Instructions for Permitted
Payment Stablecoin Issuers Subject to the Jurisdiction of the Office of
the Comptroller of the Currency,'' that would include weekly and
quarterly reporting forms that must be completed by permitted payment
stablecoin issuers and foreign payment stablecoin issuers. The OCC is
seeking a new OMB control number for this information collection. The
OCC also is giving notice that it has sent the collection to OMB for
review.
DATES: Comments must be received by November 23, 2026.
ADDRESSES: Commenters are encouraged to submit comments by email, if
possible. You may submit comments by any of the following methods:
<bullet> Email: <a href="/cdn-cgi/l/email-protection#334341525a5d555c735c50501d47415652401d545c45"><span class="__cf_email__" data-cfemail="1d6d6f7c74737b725d727e7e33696f787c6e337a726b">[email protected]</span></a>.
<bullet> Mail: Chief Counsel's Office, Attention: Comment
Processing, Office of the Comptroller of the Currency, Attention: 1557-
NEW, 400 7th Street SW, Suite 1E-216, Washington, DC 20219.
<bullet> Hand Delivery/Courier: 400 7th Street SW, Suite 1E-216,
Washington, DC 20219.
<bullet> Fax: (571) 293-4835.
Instructions: You must include ``OCC'' as the agency name and
``1557-NEW'' in your comment. In general, the OCC will publish comments
on <a href="http://www.reginfo.gov">www.reginfo.gov</a> without change, including any business or personal
information provided, such as name and address information, email
addresses, or phone numbers. Comments received, including attachments
and other supporting materials, are part of the public record and
subject to public disclosure. Do not include any information in your
comment or supporting materials that you consider confidential or
inappropriate for public disclosure.
Written comments and recommendations for the proposed information
collection should also be sent within 30 days of publication of this
notice to <a href="http://www.reginfo.gov/public/do/PRAMain">www.reginfo.gov/public/do/PRAMain</a>. You can find this
information collection by selecting ``Currently under 30-day Review--
Open for Public Comments'' or by using the search function.
You may review comments and other related materials that pertain to
this information collection following the close of the 30-day comment
period for this notice by the method set forth in the next bullet.
<bullet> Viewing Comments Electronically: Go to <a href="http://www.reginfo.gov">www.reginfo.gov</a>.
Hover over the ``Information Collection Review'' tab and click on
``Information Collection Review'' from the drop-down menu. From the
``Currently under Review'' drop-down menu, select ``Department of the
Treasury'' and then click ``submit.'' This information collection can
be located by searching OMB control number ``1557-NEW'' or ``Reporting
Forms and Instructions for Permitted Payment Stablecoin Issuers Subject
to the Jurisdiction of the Office of the Comptroller of the Currency.''
Upon finding the appropriate information collection, click on the
related ``ICR Reference Number.'' On the next screen, select ``View
Supporting Statement and Other Documents'' and then click on the link
to any comment listed at the bottom of the screen.
For assistance in navigating <a href="http://www.reginfo.gov">www.reginfo.gov</a>, please contact the
Regulatory Information Service Center at (202) 482-7340.
FOR FURTHER INFORMATION CONTACT: Shaquita Merritt, Clearance Officer,
(202) 649-5490, Chief Counsel's Office, Office of the Comptroller of
the Currency, 400 7th Street SW, Washington, DC 20219. If you are deaf,
hard of hearing, or have a speech disability, please dial 7-1-1 to
access telecommunications relay services.
SUPPLEMENTARY INFORMATION: Under the PRA (44 U.S.C. 3501 et seq.),
Federal agencies must obtain approval from the OMB for each collection
of information that they conduct or sponsor. ``Collection of
information'' is defined in 44 U.S.C. 3502(3) and 5 CFR 1320.3(c) to
include agency requests or requirements that members of the public
submit reports, keep records, or provide information to a third party.
The OCC asks the OMB to approve the collection in this notice.
Title: Reporting Forms and Instructions for Permitted Payment
Stablecoin Issuers Subject to the Jurisdiction of the Office of the
Comptroller of the Currency.
OMB Control No.: 1557-NEW.
Type of Review: Regular.
Affected Public: Businesses or other for-profit.
Description: The Guiding and Establishing National Innovation for
U.S. Stablecoins Act (12 U.S.C. 5901 et seq.) (GENIUS Act or the Act)
was enacted on July 18, 2025. The GENIUS Act establishes a regulatory
framework for payment stablecoin activities. On March 2, 2026, the
Office of the Comptroller of the Currency (OCC) issued a proposed rule
that would implement requirements of the Act with respect to the
issuance of payment stablecoins and certain related activities by
entities subject to the OCC's jurisdiction (the proposed rule).\1\ On
[[Page 66917]]
June 12, 2026, the OCC proposed weekly and quarterly reporting forms
(Form PS-01 and Form PS-02, respectively) that permitted payment
stablecoin issuers and foreign payment stablecoin issuers subject to
the OCC's jurisdiction would be required to file with the OCC.\2\ The
OCC issued a final rule implementing the requirements of the GENIUS Act
with respect to the issuance of payment stablecoins and certain related
activities by entities subject to the OCC's jurisdiction (the final
rule), published elsewhere in this issue of the Federal Register.\3\
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\1\ See Implementing the Guiding and Establishing National
Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins
by Entities Subject to the Jurisdiction of the Office of the
Comptroller of the Currency, 91 FR 10202 (March 2, 2026).
\2\ 91 FR 35795; OCC Bulletin 2026-24, ``GENIUS Act: Reporting
Forms and Instructions for Permitted Payment Stablecoin Issuers
Subject to the Jurisdiction of the Office of the Comptroller of the
Currency,'' (June 11, 2026), <a href="https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-24.html">https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-24.html</a>.
\3\ See the final rule titled Implementing the Guiding and
Establishing National Innovation for US Stablecoins Act for the
Issuance of Stablecoins by Entities Subject to the Jurisdiction of
the Office of the Comptroller of the Currency published elsewhere in
this issue of the Federal Register.
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These reporting forms would help ensure compliance with the final
rule, facilitate OCC supervision of permitted payment stablecoin
issuers and foreign payment stablecoin issuers, and would promote
transparency with respect to the financial condition of permitted
payment stablecoin issuers and foreign payment stablecoin issuers.
Twelve CFR 15.14 of the final rule requires a permitted payment
stablecoin issuer to submit two reports to the OCC. Section 15.14(h)
requires a permitted payment stablecoin issuer to submit a weekly
confidential reporting form to the OCC for each payment stablecoin it
issues, and section 15.14(i) requires a permitted payment stablecoin
issuer to submit a quarterly reporting form to the OCC. Section
15.31(b)(2) of the final rule requires a foreign payment stablecoin
issuer registered with the OCC to produce the reports required of a
permitted payment stablecoin issuer under section 15.14. With this
issuance, the OCC is publishing a revised set of the required weekly
and quarterly reporting forms for public comment. The revised reporting
forms, and their instructions, are available at <a href="http://www.occ.gov">www.occ.gov</a>. The
proposed forms are published as text documents. However, the OCC
expects to use eXtensible Markup Language (commonly known as ``XML'')
or another format for permitted payment stablecoin issuers to submit
reported data to enhance usability of the data. The final rule will be
effective on January 18, 2027. This information collection would take
effect as of the January 25, 2027, report date for OCC Reporting Form
PS-01, Payment Stablecoin Activity and Reserve Weekly Reporting, and
the March 31, 2027, report date for OCC Reporting Form PS-02, Permitted
Payment Stablecoin Issuer and Foreign Payment Stablecoin Issuer Reports
of Condition and Income.
Comments: On June 12, 2026, the OCC published a 60-day notice for
this proposed information collection.\4\ The agency received several
public comments for the agency's consideration.
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\4\ See 91 FR 35795.
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General Comments Regarding Forms PS-01 and PS-02
On June 12, 2026, the OCC proposed a weekly reporting form, Form
PS-01, and a quarterly reporting form, Form PS-02, that permitted
payment stablecoin issuers and foreign payment stablecoin issuers,
subject to the OCC's jurisdiction, would be required to file with the
OCC. The notice accompanying the forms invited comment on Forms PS-01
and PS-02 generally as well as certain technical aspects of the forms.
The comment period closed on August 11, 2026, and the OCC received
approximately 20 comments in total. The comments focused on numerous
aspects of the proposed forms as well as the overall reporting
framework. Below is a discussion of the comments the OCC received
concerning the overall reporting framework and technical comments that
apply to both Form PS-01 and Form PS-02. Comments specific to Form PS-
01 and Form PS-02 are discussed below.
One commenter expressed support for a reporting framework that is
targeted, risk-based, and aligned with the GENIUS Act and encouraged
the OCC to tailor the reporting obligations to capture information most
important to assessing compliance with the GENIUS Act's core
requirements, while avoiding imposing duplicative or impracticable
obligations. In response to this feedback, the OCC has revised the
reporting forms to minimize duplication, reduce the overall reporting,
and ensure that the information being collected from permitted payment
stablecoin issuers and foreign payment stablecoin issuers is essential
to the supervision of those entities. Upon implementation, the OCC will
continue to assess the reporting forms to ensure that the data being
reported serves a justifiable supervisory purpose and provides the OCC
with information relevant to the supervision of permitted payment
stablecoin issuers and foreign payment stablecoin issuers.
Several commenters expressed support for the issuance of a
reporting framework jointly adopted by the primary Federal payment
stablecoin regulators. Generally, the commenters stated that jointly
adopted reporting forms would improve consistency of reporting, reduce
burden, and align with the statutory mandate in the GENIUS Act for
Federal payment stablecoin regulators. One commenter stated that the
primary Federal payment stablecoin regulators should coordinate closely
to ensure that reporting requirements for all federal qualified payment
stablecoin issuers are substantially similar. Another commenter stated
that harmonization is key to ensuring that permitted payment stablecoin
issuers compete on a level compliance field, while also enabling the
Federal payment stablecoin regulators to evaluate the same core
information through consistent, comparable reporting metrics. Another
commenter stated that a review of the reporting forms and instructions
published by the OCC and Federal Deposit Insurance Corporation
(``FDIC'') found mostly identical definitions but that there were a few
notable differences between the OCC's and the FDIC's respective
forms.\5\ The commenter claimed that differences in definitions,
labels, or calculation relationships can result in inconsistencies and
lack of interoperability between datasets, which makes it not only
difficult to compare and analyze, but also limits the Federal payment
stablecoin regulators' ability to share tools and platforms for
collection and use. The commenter further stated that harmonizing the
reporting requirements and terminology will make it easier and less
expensive for the industry to implement. Another commenter stated that
the OCC should coordinate with the other primary Federal payment
stablecoin regulators so that common fields have the same meaning,
which would improve comparability, reduce reconciliation risk, and
minimize duplicative reporting burdens for permitted payment stablecoin
issuers subject to multiple Federal reporting or supervisory
expectations.
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\5\ 91 FR 45274; FDIC Financial Institution Letter, ``GENIUS
Act: Proposed Reporting Forms and Instructions for FDIC-Supervised
Permitted Payment Stablecoin Issuerss,'' (July 17, 2026), <a href="https://www.fdic.gov/news/financial-institution-letters/2026/genius-act-proposed-reporting-forms-and-instructions-fdic">https://www.fdic.gov/news/financial-institution-letters/2026/genius-act-proposed-reporting-forms-and-instructions-fdic</a>. The FDIC published:
(1) a weekly confidential reporting form (``FDIC PS-01''); and (2) a
quarterly reporting form (``FDIC PS-02''). The FDIC also proposed a
``short-form'' weekly report for eligible FDIC-supervised permitted
payment stablecoin issuers (``FDIC PS-01a'').
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[[Page 66918]]
The OCC has, and continues to, coordinate closely with the other
primary Federal payment stablecoin regulators. Further, the OCC has
taken seriously its obligation to coordinate with other agencies, as
appropriate, and does not believe that it is necessary to do so through
joint reporting forms. The GENIUS Act vests the primary Federal payment
stablecoin regulators with varying regulatory and supervisory mandates
and each primary Federal payment stablecoin regulator must develop
reporting that best serves those mandates. The OCC will continue to
coordinate with the other primary Federal payment stablecoin regulators
to develop consistent terminology, minimize duplication, and reduce
burden, as appropriate.
The OCC also received several comments recommending the delay or
re-proposal of the reporting forms until after the final rule is
published. Specifically, several commenters stated that the OCC should
repropose the reporting forms to reflect the regulatory requirements
after the substantive requirements for permitted payment stablecoin
issuers have been adopted. One commenter noted that because the
proposed substantive rule is still outstanding and not yet final, the
proposed reporting forms include flexibility and may be subject to
change. Another commenter stated that at a minimum, the OCC should
delay finalization and issue revised forms for additional comment after
its own and the related frameworks to be developed by the other primary
Federal payment stablecoin regulators are finalized. The commenters
added that this approach would help ensure that commenters can evaluate
the reporting forms within a sufficiently complete regulatory
framework. Another commenter encouraged the OCC to ensure permitted
payment stablecoin issuers are provided a reasonable implementation
period to establish systems to comply with the OCC's finalized
reporting regime.
The OCC issued the final rule published elsewhere in this issue of
the Federal Register, and the final rule will be effective as of
January 18, 2027, and the first weekly report will be due on January
27, 2027, and the first quarterly report for the quarter ending on
March 31, 2027, will be due no later than April 30, 2027.\6\ The OCC is
publishing the revised reporting forms following the issuance of the
final rule to allow the public an opportunity to provide comment on the
revised reporting forms. Further, by publishing the revised forms for
comment in October 2026, permitted payment stablecoin issuers should
have sufficient time to implement the necessary systems to comply with
the weekly and quarterly reporting requirements before the reporting
forms' effective dates.
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\6\ See the final rule titled Implementing the Guiding and
Establishing National Innovation for US Stablecoins Act for the
Issuance of Stablecoins by Entities Subject to the Jurisdiction of
the Office of the Comptroller of the Currency published elsewhere in
this issue of the Federal Register.
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The OCC also received several comments expressing support for
machine-readable reporting and providing recommendations regarding
format. One commenter expressed support for the use of XML or another
format for permitted payment stablecoin issuers to submit reported data
to enhance usability. The commenter further stated that the OCC should
describe and propose the reporting architecture, data-governance
framework, validation processes, analytical capabilities, public-
dissemination approach, interagency data sharing mechanisms, and
supervisory workflows that will support the forms. Another commenter
recommended the OCC require weekly and quarterly reporting to be
prepared in the open eXtensible Business Reporting Language (commonly
known as ``XBRL'') semantic data model. Another commenter recommended
that the OCC specify a structured, machine-readable filing format for
both reporting forms, using the XBRL standard already in production
across the federal banking agencies for Consolidated Reports of
Condition and Income filings, commonly referred to as ``Call Reports,''
collection since 2005. Finally, another commenter recommended the use
of a full XBRL taxonomy.
Several commenters also provided additional feedback on
supplemental information that the OCC should make available to support
the implementation of the chosen machine-readable format. Specifically,
the commenters recommended that the OCC supplement any XML or other
machine-readable submission format with a common data dictionary,
machine-readable schemas, automated edit checks, standardized
identifiers, inter-schedule consistency checks, data-quality reviews,
exception reporting, and clear rules governing the treatment of null,
zero, unavailable, amended, and restated data.
As discussed in the final rule, on June 25, 2026, pursuant to the
Financial Data Transparency Act (FDTA),\7\ the OCC and other Federal
agencies issued a joint final rule establishing joint data
standards.\8\ In addition to the joint rule, the FDTA also directs each
agency to issue individual rules adopting applicable joint standards
for certain collections of information under their respective purview.
The OCC has not issued its agency-specific rulemaking adopting
applicable joint standards. In developing and finalizing the weekly and
quarterly reporting forms, the OCC will ensure that the reporting forms
are consistent with the FDTA and the agencies' joint rule. Of note, the
OCC will be able to accept some ISO 20022 structures, such as XML.
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\7\ See The Financial Data Transparency Act of 2022, Public Law
117-263, title LVIII, 136 Stat. 3421.
\8\ See Financial Data Transparency Act Joint Data Standards, 91
FR 38246 (June 25, 2026).
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One commenter observed that the reporting forms do not contain a
validation artifact, no taxonomy, no schema, and no edit-check
specification accompany the forms. The commenter also observed that
neither set of instruction documents contains a validation or data-
quality section and the general instructions affirmatively permit
signed entries. Another commenter recommended that the forms and
instructions permit, without requiring, reported figures to carry
independently verifiable evidence.
The OCC believes it is unnecessary for permitted payment stablecoin
issuers to provide accompanying data with their weekly and quarterly
reporting filings. Permitted payment stablecoin issuers are required to
have internal controls and information systems that ensure ``[t]imely
and accurate financial, operational, and regulatory reporting,
including with respect to the reports required under this part.'' \9\
Further, where a permitted payment stablecoin issuer supplies
inaccurate data, the forms' instructions require permitted payment
stablecoin issuers to correct those inaccuracies by filing amended
reports. With respect to quarterly filings, a permitted payment
stablecoin issuer's senior management and board of directors are
required to attest to the accuracy of the data being reported to the
OCC.\10\ Finally, if the OCC believes a permitted payment stablecoin
issuer is providing inaccurate data, the OCC has both the ability to
require the permitted payment stablecoin issuer to provide additional
reports and to examine a permitted payment stablecoin issuer's books
and records.\11\ For these reasons, the OCC does not believe it is
necessary
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\9\ See 12 CFR 15.13(a)(iii).
\10\ See 12 CFR 15.14(i).
\11\ See 12 CFR 15.14(b), (e), and (j).
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[[Page 66919]]
to allow permitted payment stablecoin issuers to provide additional
documentation with their weekly or quarterly submissions.
In addition, prior to implementation of the final rule, the OCC
will publish an accompanying document detailing the technical
specifications for Forms PS-01 and PS-02. This documentation will
provide technical information such as the data dictionary and edit-
checks, the XML schemas, sample XML files, along with filing
instructions.
The OCC received several comments recommending the use of legal
entity identifiers (commonly referred to as ``LEIs'') in the reporting
forms. The commenters stated that the use of LEIs would provide
certainty to the public, provide standardization, and promote
efficiency and transparency. The OCC notes that the instructions for
proposed Forms PS-01 and PS-02 provide for the use of LEIs. However,
the instructions do not require a permitted payment stablecoin issuer
to obtain an LEI for purposes of filing either Form PS-01 or Form PS-
02. The instructions for the revised forms continue to allow for the
use of LEIs but maintain that this is not a requirement. As part of its
agency-specific rulemaking implementing the FDTA, the OCC will assess
how to incorporate the data standards, including LEI, established by
joint rulemaking into its collections of information.
One commenter recommended that the OCC consider adding a
supplemental Payment Stablecoin Infrastructure schedule to Forms PS-01
and PS-02. The commenter explained that the schedule could provide a
standardized operational record addressing six principal categories:
Capacity and Performance; Transaction Reliability; Settlement and
Finality; Ordering and Economic Detriment; Operational Resilience and
Dependencies; and Data Provenance and Verification.
The OCC declines to add the proposed schedule to Forms PS-01 or PS-
02 because the information is too granular. To the extent necessary,
the OCC could obtain similar information through the supervisory
process or through the request of additional reporting.\12\ Following
implementation, the OCC will continue to assess the reporting forms and
consider implementing elements of the proposed schedule in the future
if appropriate.
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\12\ See 12 CFR 15.14(a) and (e), which concern the OCC's
authority to examine permitted payment stablecoin issuers; see also
12 CFR 15.14(j)(2), which requires permitted payment stablecoin
issuers, upon request, to submit reports concerning the ``systems of
the permitted payment stablecoin issuer for monitoring and
controlling financial and operational risks.''
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The OCC also received comments concerning the aspects of the
proposal related to the reporting requirements for foreign payment
stablecoin issuers. One commenter expressed the view that the OCC
should not default to a ``one-size-fits-all'' reporting regime for both
permitted payment stablecoin issuers and foreign payment stablecoin
issuers and urged the OCC to tailor the information required of a
foreign payment stablecoin issuers to what is reasonably necessary for
the OCC to assess a foreign payment stablecoin issuer's U.S. payment
stablecoin activities and its compliance with the GENIUS Act. The
commenter explained that an appropriately tailored and flexible
reporting regime for foreign payment stablecoin issuers will further
cross-border collaboration in digital financial innovation using
payment stablecoins. The same commenter further stated that the OCC
should consider which data items in Forms PS-01 and PS-02 are truly
necessary to supervise a foreign payment stablecoin issuer's U.S.
operations and should exempt foreign payment stablecoin issuers from
unnecessary data items. As an example, the commenter stated in Form PS-
01, instead of asking for a foreign payment stablecoin issuer's top
five counterparties and top 100 exchanges worldwide, those items could
be limited to the top five U.S. counterparties and the top 100
exchanges that make the foreign payment stablecoin issuer's payment
stablecoins available in the U.S.
With regard to quarterly reporting for foreign payment stablecoin
issuers, the commenter expressed the view that foreign payment
stablecoin issuers could provide a simplified version of Form PS-02's
income statement that does not require a detailed breakdown of income
streams and expenses for different types of reserve assets in proposed
Schedule A, Items 1 and 2 and for other income sources and other
expenses in proposed Schedule A, Items 4 and 5. The commenter explained
that a simplified approach to ``other'' income and expenses in Items 4
and 5 would appropriately reflect the fact that foreign payment
stablecoin issuers may have somewhat different activities, income
sources, and expenses than domestic permitted payment stablecoin
issuers, while still providing the OCC and the public with sufficient
information on the foreign payment stablecoin issuer's financial
performance. The same commenter also recommended that the OCC permit
foreign payment stablecoin issuers to elect to satisfy their reporting
obligations with reasonably equivalent reports prepared for their home
country regulators.
The commenter also recommended that the OCC permit foreign payment
stablecoin issuers to submit their weekly and quarterly reporting forms
in accordance with the International Financial Reporting Standards
(``IFRS'') to avoid imposing unnecessary compliance burdens on foreign
payment stablecoin issuers. The commenter explained that because
foreign payment stablecoin issuers are organized or domiciled outside
the United States, many foreign payment stablecoin issuers will prepare
their home country reports and audited financial statements according
to IFRS.
The OCC declines to tailor the reporting forms for foreign payment
stablecoin issuers or allow foreign payment stablecoin issuers to
satisfy their reporting obligations through the submission of reports
generated for compliance in their home jurisdiction. Under the final
rule, foreign payment stablecoin issuers are required to file the same
reports as permitted payment stablecoin issuers.\13\ Following
implementation of the final rule, the OCC will assess the reporting
forms and consider whether the reporting forms, or some aspect of the
forms, should be tailored for foreign payment stablecoin issuers.
Issuer-specific and jurisdiction specific-issues related to the
reporting forms may also be addressed as a condition of licensing or
under comparability determinations or reciprocity agreements created by
the Secretary of the Treasury, under section 18 of the GENIUS Act (12
U.S.C. 5916). The OCC notes that a foreign payment stablecoin issuer
may request, and the OCC may provide, an exemption from a reporting
requirement.\14\ Thus, the final rule provides an avenue for reducing
burden on a case-by-case basis.
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\13\ See 12 CFR 15.31(b).
\14\ See id. at (b)(2).
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The OCC also declines to allow foreign payment stablecoin issuers
to report in IFRS because several requirements in the final rule are
tied to U.S. Generally Accepted Accounting Principles (``GAAP'')
reporting--e.g., fair value and capital instruments.\15\ Further,
allowing foreign payment stablecoin issuers to report in IFRS would
limit comparability across payment stablecoin issuers. For these
reasons, the OCC is maintaining the requirement that foreign payment
stablecoin issuers report in GAAP.
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\15\ See 12 CFR 15.2; and 15.40(a), (b)(1).
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The commenter also stated that foreign payment stablecoin issuers
[[Page 66920]]
should be provided with a clear process to request confidential
treatment for data items that are subject to non-disclosure
requirements or protected under applicable home country law or
constitute trade secrets. The OCC notes that the instructions for
proposed Form PS-02 details the process for requesting confidential
treatment of certain information. Both foreign payment stablecoin
issuers and permitted payment stablecoin issuers may request
confidential treatment of information contained in Form PS-02. The OCC
further notes that this concern does not apply to Form PS-01 because
the data reported through Form PS-01 is strictly for supervisory
purposes and will remain confidential.
The OCC also received feedback related to the filing of amended
forms. Specifically, a commenter stated that the OCC should replace the
proposed five calendar-day deadline by which payment stablecoin issuers
would be required to produce amended filings with a more flexible
deadline. The commenter stated that in many cases, five days is
unlikely to be enough time to identify, reconcile, verify, and report
an error. The commenter added that historical revisions may require
significant resources to identify affected periods, reconstruct and
reconcile data, and to prepare and file an accurate restatement.
In response to this comment, the OCC has amended the proposed
instructions for Forms PS-01 and PS-02 to remove the requirement that
amended filings be made within five calendar days of discovery. The OCC
made this revision to the instructions to provide permitted payment
stablecoin issuers with increased flexibility to address omissions or
significant errors. However, the removal of the five-calendar-day
deadline for filing amended reports is not intended to suggest that
permitted payment stablecoin issuers are relieved of their obligation
to correct forms containing omissions or significant errors in a timely
manner. A permitted payment stablecoin issuer should contact their
supervisory team if it is unclear about its obligations to address
omissions or significant errors in its reporting forms in an
appropriate timeframe.
The OCC also received comments and feedback concerning technical
elements of the reporting forms. The comments largely recommended that
the OCC clarify certain aspects of the reporting forms and
instructions. One commenter requested that the OCC confirm how bridged
and wrapped representations should be treated.\16\ The commenter
recommended that representations the permitted payment stablecoin
issuer did not create should not count toward their outstanding
issuance value and should be disclosed separately. The same commenter
also suggested the OCC confirm how restricted balances interact with
reported outstanding supply, so that the reported figure can be
compared with observable network supply.
---------------------------------------------------------------------------
\16\ ``Wrapping'' is a process where a crypto-asset is provided
to a wrapped token provider, the provider controls or
programmatically locks up the crypto-asset in a way that it cannot
be transferred, lent, pledged, rehypothecated, or otherwise used for
any reason, then mints a new crypto-asset in the form of a
redeemable wrapped token. The redeemable wrapped token confers to
the holder the right to ``un-lock'' the original crypto-asset from
the wrapped token provider and is designed so that the number of
redeemable wrapped tokens outstanding equals the underlying crypto-
assets wrapped. Wrapped tokens are primarily used to enhance
interoperability between blockchains by creating a redeemable
wrapped token that is issued on a different blockchain than the
original crypto-asset, effectively allowing holders to transact
crypto-assets on blockchains they are not natively minted on.
``Bridging'' is the process of moving a crypto-asset from one
blockchain to another or creating a redeemable wrapped token on a
different blockchain than the underlying crypto-assets. Crypto-asset
issuers that can mint and burn their crypto-asset on multiple
blockchains may offer the ability to natively ``bridge'' crypto-
assets. They do this by accepting their crypto-asset issued on one
blockchain, burning, or permanently removing it from circulation,
and simultaneously minting it on another blockchain. The new crypto-
asset has been permanently transferred to the second blockchain
while the overall supply of crypto-assets issued by the provider
remains the same. In contrast, a wrapped token provider may provide
``bridging'' services. However, as described above, the resulting
crypto-asset is a redeemable wrapped token. It does not burn or
alter the original crypto-asset in any way.
---------------------------------------------------------------------------
The OCC does not believe any clarification concerning the treatment
of bridged or wrapped stablecoins is required. First, the definition of
payment stablecoin, in part, states that a permitted payment stablecoin
issuer has an obligation to redeem the payment stablecoin for a fixed
amount of monetary value.\17\ A permitted payment stablecoin issuer
would not have an obligation to redeem bridged or wrapped stablecoins.
With respect to restricted stablecoins, the OCC, again, does not
believe any additional clarity is necessary. Whether a restricted
stablecoin meets the definitions of a payment stablecoin may depend on
the facts and circumstances of that payment stablecoin. Permitted
payment stablecoin issuers will determine whether payment stablecoins
that have been minted meet the definition of a payment stablecoin and
whether they are issued to be considered part of outstanding issuance
value. If a restricted payment stablecoin remains a liability of the
permitted payment stablecoin issuer because the payment stablecoin may
be redeemed in the future, then the payment stablecoin is part of the
permitted payment stablecoin issuer's outstanding issuance value and a
permitted payment stablecoin issuer must maintain reserves backing the
outstanding stablecoin and the associated liability.
---------------------------------------------------------------------------
\17\ See 12 CFR 15.2.
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Another commenter stated that the OCC should consider collecting
instrument-level detail for tokenized reserve assets. The commenter
explained that a tokenized claim can trade away from the value of the
asset it references, which bears on fair-value reserve coverage.
The OCC concurs with this recommendation and has updated the
reporting forms, as discussed below, to require a permitted payment
stablecoin issuer to indicate if a reserve asset is tokenized. The OCC
believes collecting this information is necessary to understand a
permitted payment stablecoin issuer's reserve asset composition, risk
profile, and concentration risk.
Another commenter stated that the OCC should explain how weekly
stablecoin-level information reported on Form PS-01 will reconcile with
quarterly entity-level information reported on Form PS-02, including
issuance, redemption, outstanding stablecoin liabilities, reserve
assets, reserve income, reserve monetization, blockchain-level
activity, custody and safekeeping, off-balance-sheet exposures, and
financial condition.
The OCC does not believe further clarification is warranted at this
time. The instructions for each form indicate the cut-off dates and
times and expectations for reported information. Upon implementation,
the OCC will monitor Forms PS-01 and PS-02 for reconciliation
challenges. If any challenges or concerns arise, the OCC will revise
the instructions to address these issues.
Another commenter observed that the OCC uses the term ``customer''
and the FDIC uses the term ``holder'' for the same purpose, although
these terms are not interchangeable. According to the commenter, under
the GENIUS Act, a customer has a direct commercial or account
relationship with a permitted payment stablecoin issuer, whereas a
holder may own or possess a stablecoin (via secondary markets or peer-
to-peer transfers) without any direct legal or operational relationship
with the issuer.
In response to this comment, the OCC has reviewed the instructions
for both Form PS-01 and Form PS-02 and made
[[Page 66921]]
revisions, as appropriate, to the instructions to ensure that the terms
``customer'' and ``holder'' are used consistent with the definitions of
those terms in the final rule.\18\
---------------------------------------------------------------------------
\18\ See 12 CFR 15.2.
---------------------------------------------------------------------------
Another commenter observed that the OCC's uses the term ``Gross
total reserve assets'' while the FDIC uses the term ``Net of repo
liabilities.'' The commenter claimed that this is a material reporting
difference that could cause confusion and misinterpretation among both
issuers and data users.
In response to this comment, the OCC, as discussed below, has
revised Forms PS-01 and PS-02 to utilize the term ``Total reserve
assets net of outstanding repurchase agreement liabilities'' to
minimize any potential for confusion.
The OCC also received recommendations for additional reporting to
supplement the weekly and quarterly reporting. One commenter
recommended that the OCC establish accelerated reporting triggers for
material peg deviations, significant redemption activity, redemption
delays, exchange liquidity disruptions, large reserve-asset
liquidations, operational outages, interruptions in access to bank
deposits or custodians, or material sanctions-related freeze or
blocking events. The commenter explained that stablecoin stress can
develop rapidly, and supervisors may benefit from more timely
information during periods of acute market stress.
The OCC declines to impose additional reporting burden on permitted
payment stablecoin issuers. If the OCC identifies concerns with a
permitted payment stablecoin issuer, the OCC has the ability to request
additional reporting from a permitted payment stablecoin issuer.\19\
Upon implementation, the OCC will assess the reporting forms to ensure
that the data being reported both serves a justifiable supervisory
purpose and provides the OCC with information relevant to the
supervision of permitted payment stablecoin issuers.
---------------------------------------------------------------------------
\19\ See 12 CFR 15.14(j).
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Proposed Weekly Reporting Form PS-01
The proposed weekly reporting forms would, among other things, help
ensure compliance with the reserve asset requirements in proposed
sections 15.11 and 15.31(a)(3). Proposed Schedule A would collect
information on top stablecoin holders and transactors and counterparty
concentration information. Proposed Schedule B would collect
information on day-over-day changes in outstanding payment stablecoins
and information redemptions. Proposed Schedule C would collect
information about a permitted payment stablecoin issuer's aggregate
composition of reserve assets for each payment stablecoin it issues.
Proposed Schedules D, E, F, G, and H would collect disaggregated
information about specific classes of reserve assets (e.g., U.S.
Treasury securities on proposed Schedule E). Permitted payment
stablecoin issuers and foreign payment stablecoin issuers would only be
required to report information regarding reserve assets held pursuant
to the GENIUS Act on Proposed Schedules C, D, E, F, G, and H. Permitted
payment stablecoin issuers and foreign payment stablecoin issuers are
not required to report information on these schedules regarding assets
they own that are not held as reserve assets or transactions in which
they have engaged unrelated to the maintenance of reserve assets. For
example, permitted payment stablecoin issuers and foreign payment
stablecoin issuers should not report U.S. Treasury securities they own
on Schedule E if those U.S. Treasury securities do not comprise the
reserve assets used to back outstanding stablecoin issuance pursuant to
the GENIUS Act.
As a part of the notice, the OCC invited comments on what items
should be modified or removed and whether any items should be added.
The OCC received feedback on numerous aspects of proposed Form PS-01.
One commenter expressed support for the collection and stated that
the weekly reporting asks for the right information at the right
cadence, and the schedule structure introduced in the proposed
rulemaking is sensible. Another commenter stated that the proposed
schedules collect information that is both available to permitted
payment stablecoin issuers and is relevant to the oversight of
permitted payment stablecoin issuers. In contrast, another commenter
stated that the proposed weekly reporting cadence has no identified
analogue in the ordinary prudential reporting the OCC requires of a
national bank in sound condition. The commenter also questioned why the
Call Report and the monthly, independently examined reserve report
leave a supervisory gap requiring a universal weekly filing. The
commenter also expressed support for adopting monthly reporting instead
of a weekly reporting cadence.
The OCC believes that requiring a permitted payment stablecoin
issuer to provide a weekly confidential set of data for each payment
stablecoin it issues will allow the agency to understand the permitted
payment stablecoin issuer's operations and the risks unique to its
business model. Monthly and quarterly reports do not provide a frequent
enough reporting cadence to oversee risks and changes, given the short
maturity of permitted payment stablecoin issuers' reserve assets. This
regular data reporting will also allow the OCC to tailor its
examinations to be risk-based, which will reduce the burden of
examinations. Further, weekly reporting will allow the agency to
identify and respond more quickly to emerging novel and financial
stability risks. The weekly reporting will remain confidential because
its primary purpose is to inform the OCC's supervision of permitted
payment stablecoin issuers and the stablecoin market.
Several commenters provided feedback about the challenges
associated with providing reliable and accurate data on a weekly basis
on the proposed timelines. One commenter claimed that Form PS-01
effectively establishes a daily reporting obligation across all eight
schedules that largely duplicates the GENIUS Act's monthly attestation
requirement. The commenter further claimed that collecting and
furnishing this data on a daily basis for consolidation into a weekly
report creates significant operational demands that, in some cases, may
not be possible or may need additional time to verify. The commenter
highlighted three categories as particularly problematic to comply
with: (i) third-party data; (ii) instrument-level reserve detail; and
(iii) operational timing. The commenter further claimed that providing
this data in near-real time also minimizes the ability to conduct data
validation and reconciliation. The commenter further added that
reporting should allow sufficient time to reconcile and evidence
reserve balances and payment stablecoins in circulation, rather than
require publication of unsupported figures. The commenter also proposed
for permitted payment stablecoin issuers in full compliance with the
attestation requirements, that the OCC substitute the weekly forms by
supplementing the attestation with a randomly selected monthly surprise
observation date. The commenter stated that this is a standard that has
been successfully used by the New York Department of Financial Services
to ensure payment stablecoin issuers maintain identifiable reserves at
all times.
Another commenter stated that requiring permitted payment
stablecoin issuers to become a routine reporting agent for third-party
trading activity is a distinct market surveillance function.
[[Page 66922]]
The commenter added that if the OCC concludes that issuer-based market
surveillance is both necessary and authorized, the requirement should
be proposed in regulatory text through coordinated notice-and-comment
rulemaking. The commenter added that the process should identify the
risk each item addresses, the decisions it will inform, the party best
positioned to supply it, and a common methodology and accuracy
standard. The commenter further added that the Tuesday-to-Wednesday
cycle leaves approximately seventeen hours to collect final data from
multiple providers, reconcile it, approve it, and submit it. The
commenter claimed that preliminary files frequently change after
settlement or valuation adjustments, which results in a forced choice
between provisional reporting and routine amendments. Two other
commenters added that requiring permitted payment stablecoin issuers to
file Form PS-01 within less than 24 hours creates a significant
recurring operational demand, while also reducing a permitted payment
stablecoin issuer's ability to validate data. Another commenter
recommended that the OCC eliminate the secondary market pricing line
items in Form PS-01 and the OCC obtain real-time pricing data instead
of requiring permitted payment stablecoin issuers to report this
information.
As discussed in greater detail below, the OCC is revising Form PS-
01 and its accompanying schedules to reduce the amount of market data
permitted payment stablecoin issuers are required to report. For
example, the OCC has removed Items 3 and 4 from proposed Schedule A,
which sought data related to trading volume of exchanges. The OCC is
eliminating these reporting categories in response to feedback received
concerning the operational and validation challenges associated with
the collection of third-party data.
In response to these comments concerning the limited amount of time
between the close of the reporting period and the reporting deadline,
the OCC has elected to maintain the Wednesday, 5:00 p.m. (Eastern)
filing deadline for Form PS-01, but revise the reporting period in the
proposed instructions for Form PS-01 from ``12:00:00 a.m. (Eastern)
each Wednesday to 11:59:59 p.m. (Eastern) the following Tuesday'' to
``12:00:00 a.m. (Eastern) each Tuesday to 11:59:59 p.m. (Eastern) the
following Monday.'' This change is being implemented to provide
permitted payment stablecoin issuers with an additional 24 hours to
prepare and submit Form PS-01.
A commenter recommended that the OCC align Form PS-01 reporting
with information maintained in a permitted payment stablecoin issuer's
books and records as of its ordinary close of business. The commenter
observed that the instructions require daily balance items as of
11:59:59 p.m. (Eastern) and daily activity based on transactions
occurring from 12:00:00 a.m. through 11:59:59 p.m. (Eastern), including
weekends and holidays. The commenter explained that those times may not
align with a permitted payment stablecoin issuer's ordinary accounting
and posting processes and could require reconstruction of activity
beyond its existing books and records. Another commenter added that
most blockchain systems currently use a Coordinated Universal Time (or
``UTC'') -based reference and shifting to Eastern time zone business
hours would add operational complexity without any commensurate
supervisory benefit.
The OCC declines to modify the instructions for Form PS-01 to allow
permitted payment stablecoin issuers to utilize their preferred close
of business. The OCC believes maintaining the 12:00:00 a.m. to 11:59:59
p.m. (Eastern) reporting period promotes consistency and comparability
across the reported data. For these reasons, the OCC is maintaining the
proposed reporting period. Following implementation of the final rule,
the OCC will monitor the reporting process to determine if changes to
the reporting instructions are warranted.
The OCC also received a range of recommendations and feedback on
the instructions for Form PS-01. Several commenters stated that
reporting with reference only to name and ticker cannot reliably
identify which specific token implementation a filing relates to. One
commenter recommended that the OCC add a standardized digital token
identifier (``DTI'') field, consistent with ISO 24165. Several
commenters also recommended that the OCC require reporting entities to
identify the blockchain using the ISO 24165 digital ledger identifier
(``DLI'') in place of or in addition to the free-text blockchain name.
In response to these comments, the OCC has amended the proposed
instructions for Form PS-01 to request a permitted payment stablecoin
issuer include the DTI for the payment stablecoin within the scope of
the form and a DLI for the blockchain network. The instructions clarify
that if a permitted payment stablecoin issuer has not obtained a DTI
for the payment stablecoin, a permitted payment stablecoin issuer is
not required to obtain a DTI for purposes of reporting Form PS-01.
Similarly, if a blockchain does not have an assigned DLI, a permitted
payment stablecoin issuer should leave the field blank.
Another commenter recommended that the OCC revise the instructions
for Form PS-01 to allow for submission of the form on the next business
day if the Wednesday deadline falls on a federal holiday. The commenter
noted that the proposed instructions for Form PS-02 state, ``If the
reporting deadline falls on a weekend or federal holiday, the form may
be submitted on the first business day following the weekend or federal
holiday.'' However, the instructions for Form PS-01, which is due every
Wednesday, do not contain a similar provision.
In response to this comment, the OCC has amended the proposed
instructions for Form PS-01 by adding language clarifying that if the
Wednesday reporting deadline falls on a federal holiday, the form may
be submitted on the first business day following the federal holiday.
The OCC also received several comments proposing reduced reporting
for smaller permitted payment stablecoin issuers. Specifically, several
commenters observed that the FDIC proposed collecting substantially
less information on a weekly basis from certain permitted payment
stablecoin issuers and encouraged the OCC to adopt a similar short form
for OCC-supervised permitted payment stablecoin issuers.
In response to these comments, the OCC considered the potential
reporting burden for smaller permitted payment stablecoin issuers and
considered proposing a truncated weekly reporting form for those
permitted payment stablecoin issuers similar to the FDIC PS-01a but
ultimately declined to propose such an approach because the OCC
believes that the proposed weekly information collection is critical to
the supervision of permitted payment stablecoin issuers, regardless of
size. Nevertheless, the OCC is amending the instructions for Form PS-01
to reduce the weekly reporting burden on smaller issuers to allow those
issuers that have an outstanding issuance value, together with any
affiliated permitted payment stablecoin issuers, of less than $1
billion, are not currently subject to a formal enforcement proceeding
or order; and are in compliance with all of the reserve and report
requirements set forth in sections 15.11 and 15.14, respectively, to
satisfy their obligations for revised Schedules D-G by only submitting
the required data for the last day of the reporting period (i.e., each
[[Page 66923]]
Monday). These qualifying criteria for reduced reporting are consistent
with the qualifying criteria for extended examination cycles under
section 15.14(d). The OCC believes this approach serves the goals of
reducing the reporting burden for smaller permitted payment stablecoin
issuers while also ensuring that the OCC receives the information
necessary to supervise permitted payment stablecoin issuers. The
instructions for revised Schedules D, E, F, and G now include
instructions noting that a permitted payment stablecoin issuer that is
eligible for reduced reporting need only to report the requested
information for the last calendar day of the reporting period.\20\ The
instructions also preserve the OCC's discretion under section 15.14(j)
to require any entity that otherwise meets the criteria to report all
schedules of Form PS-01 based on risk or supervisory needs.
---------------------------------------------------------------------------
\20\ As discussed below, the OCC is consolidating proposed
Schedule A and Schedule B, so revised Form PS-01 no longer includes
Schedule H.
---------------------------------------------------------------------------
Another commenter stated that the weekly reporting instructions
require eight schedules containing daily data to be submitted weekly
through OCC's BankNet, but do not specify the Excel file structure. The
commenter stated that the OCC should clarify whether a filing should
include separate daily workbooks for each schedule, submitted together
as one weekly filing, or a single workbook that repeats each schedule
for every reporting day. The commenter further stated that the OCC also
should specify the required workbook and worksheet structure, file-
naming convention, and submission packaging.
Following the publication of Forms PS-01 and PS-02, and in advance
of the effective date of the final rule, the OCC will publish filing
instructions so that permitted payment stablecoin issuers have notice
of the filing format and procedures. This documentation will include
technical information such as the data dictionary and edit-checks, the
XML schemas, and sample XML files.
Proposed Form PS-01--Schedules A Through G
Proposed Form PS-01 contained eight schedules--Schedules A through
H. As discussed below, the OCC has consolidated proposed Schedule A and
Schedule B from revised Form PS-01. As a result, revised Form PS-01 now
contains seven schedules--Schedule A through G. Below is a discussion
of the proposed schedules, comments the OCC received related to the
proposed schedules, and the changes the OCC is incorporating into
revised Schedules A through G.
Schedule A--General
Proposed Schedule A would collect information on the largest
holders of a stablecoin issued by a permitted payment stablecoin issuer
or foreign payment stablecoin issuer (listed by wallet address),
exchanges facilitating trading of that stablecoin, the trading volume
of the stablecoin, and the top counterparties of a permitted payment
stablecoin issuer or foreign payment stablecoin issuer.
The agency sought feedback on the collection of information in
proposed Schedule A. Specifically, the OCC asked if this is the right
type of information for the agency to collect to monitor primary and
secondary market dynamics, including during times of stress. The OCC
also asked if there are adjustments that should be made to make this
information more valuable or less burdensome. For example, should the
agency collect a fewer number of wallet addresses or exchanges and what
would be the potential advantages or disadvantages of doing so.
Finally, the agency asked if there is other information the agency does
not propose to collect that would give better insight into primary and
secondary market dynamics. In response to these prompts, the OCC
received numerous comments related to proposed Schedule A and the
information the OCC proposed to be collected.
One commenter explained that because exchange and venue addresses
will constitute a substantial share of the addresses holding the
largest balances, Item 1 will to a significant extent restate, in an
anonymous alphanumeric unit, information that Item 3 collects in a
named and directly usable one. The commenter also claimed that Items 1
and 2 of Schedule A together produce as many as 1,400 address-level
observations in each weekly filing. The commenter also observed that
FDIC PS-01a collects only the ten largest wallet addresses and
blockchains that exceed 2 percent of total outstanding issuance. The
commenter explained that the supervisory content of a concentration
item lies in the positions large enough to bear on concentration; a
position below a stated threshold does not inform that assessment, and
its collection is burden without corresponding utility. The commenter
further added that a threshold also makes the size of the collection a
function of the market rather than of an arbitrary row count: where
holdings are genuinely dispersed, few rows are reported, which is
itself the supervisory answer.
Several commenters also provided feedback on proposed Schedule A's
collection of the ``Top 100 payment stablecoin wallet addresses by
trading volume.'' One commenter stated that the instructions should
specify whether the table is intended to capture activity involving
centralized exchanges, decentralized exchanges, or both, and that the
OCC should explain how an issuer should report activity attributable to
a centralized exchange, where customer trading generally occurs off-
chain on the exchange's internal ledger and therefore may not be
visible at the individual wallet-address level on the relevant
blockchain. Another commenter noted that footnote 1 to the instructions
states that the OCC proposes to define ``trading volume'' as the
aggregate number of payment stablecoins issued by a permitted payment
stablecoin issuer or foreign payment stablecoin issuer that were
purchased or sold on exchanges during a specified period of time. The
commenter stated that this item requests information that a reporting
issuer does not generate and has no means of obtaining from any source
within its control. Schedule A, Items 3 and 4 already collect trading
volume at the exchange level, from the entities that hold the execution
data and that can be identified by legal name, and item 3 supplies the
venue population used by the Schedule B pricing items. The commenter
requested that the OCC remove Schedule A, Item 2 and retain Items 3 and
4. Another commenter encouraged the OCC to remove the reporting of
third-party data and not expect issuers to certify secondary-market
data beyond what they can reasonably obtain and validate. Similarly,
another commenter stated that the OCC should remove requirements for a
permitted payment stablecoin issuer to report information that is
derived from information held by exchanges, such as items 3 and 4 from
Form PS-01, Schedule A regarding exchange trading volume or item 2 from
Form PS-01, Schedule B regarding secondary market pricing. Another
commenter observed that proposed Schedule A would require reporting on
the daily trading volume across top exchanges and other daily volume
figures. However, according to the commenter, it is unclear whether
permitted payment stablecoin issuers would be required to report the
daily average for the week or the daily average for each day of the
reporting week. If the former, the commenter recommended
[[Page 66924]]
that the instructions clarify this approach. If the latter, the
commenter recommended updating the reporting template to present how
daily volumes should be reported for each day of the reporting week.
One commenter stated that Form PS-01 should supplement wallet-
address reporting with information regarding major direct redemption
counterparties, custodians, exchanges, omnibus accounts, affiliates,
and beneficial ownership concentrations where known. The commenter
explained that wallet-address concentrations may not necessarily
correspond to economic concentrations. The commenter added that a
single wallet address may represent an exchange, custodian, omnibus
account, liquidity pool, affiliate, bridge, or other intermediary
relationship serving numerous customers, while economically significant
holders may maintain positions across multiple wallet addresses and
blockchains. As a result, wallet-level data may not fully identify the
entities capable of generating significant redemption activity or
transmitting stress through primary and secondary markets. Another
commenter recommended retaining a shorter address list for
investigative purposes and adding an aggregated distribution view for
each stablecoin on each network. The commenter claimed that this would
be both more informative and less burdensome.
Another commenter stated that the OCC should ensure that any
collection of large-holder information by wallet address is subject to
the highest levels of confidentiality. The commenter stated that robust
privacy protections are essential given the unique transparency of
public blockchains, where wallet addresses can be linked, directly or
indirectly, to identifiable persons through blockchain analytics or
off-chain data sources. Another commenter stated that the OCC should
modify its requirement to report the top 100 stablecoin wallet
addresses in Form PS-01 to instead require reporting of wallets holding
the greater of $10 million or 1% of outstanding supply for any given
stablecoin. According to the commenter, absent supply-based tailoring,
the current top 100 wallet reporting requirement could produce
unhelpful results for payment stablecoins with small issuance volumes.
Another commenter stated that the address and the holder are distinct
units, and that the difference bears directly on whether the item
delivers the information the notice describes. The commenter explained
that a single person may control any number of addresses, and nothing
in the collection would disclose that those addresses are commonly
controlled. Conversely, a single address may hold payment stablecoins
on behalf of a large number of unrelated persons. The commenter claimed
that for a payment stablecoin in general circulation, the addresses
holding the largest balances are predominantly infrastructure
addresses: omnibus accounts operated by centralized exchanges, bridge
contracts, and liquidity pool addresses associated with automated
market makers. Another commenter stated that the OCC should replace the
proposed ``largest holders by wallet address'' field with reporting on
the permitted payment stablecoin issuer's largest direct customers,
minters, redeemers, and other direct counterparties within the
permitted payment stablecoin issuer's own perimeter. The commenter
added that a wallet address does not necessarily correspond to a single
holder, customer, beneficial owner, or risk exposure, and issuers often
will not have reliable visibility into beneficial ownership across
wallets at exchanges, custodians, intermediaries, decentralized venues,
or in secondary-market transfers.
Another commenter stated that the OCC should consider whether
additional venue-level information is necessary to identify
concentrated pricing dislocations, liquidity migration, market
fragmentation, or emerging stress at particular trading venues. The
commenter explained that trading volume alone is not a sufficient
measure of market quality because elevated volume may reflect healthy
liquidity, arbitrage activity, liquidity migration, market stress, or
forced selling. The commenter noted that the OCC recognized that
exchange-specific activity is relevant by requiring reporting on the
top 100 exchanges by trading volume and by calculating key pricing
metrics, including minimum price, maximum price, estimated secondary-
market price, peg deviation, and bid/ask spread, using data from the
top 15 exchanges. However, according to the commenter, many of these
secondary-market indicators are reported only as aggregated measures
across those exchanges. The commenter added that venue-level
information may provide greater visibility into whether adverse market
conditions are isolated to a specific exchange or reflect broader
deterioration in stablecoin market liquidity and resilience.
Consolidation of Proposed Schedule A and Schedule B
In response to the above comments concerning proposed Schedule A,
the OCC has eliminated certain items in Schedule A from revised Form
PS-01. The OCC believes the removal of these items in proposed Schedule
A serves the dual purpose of reducing the burden associated with
reporting Form PS-01 and ensuring that the information obtained from
permitted payment stablecoin issuers is relevant to the supervision of
those entities. As discussed further below, Item 1 (Top 100 payment
stablecoin wallet addresses by number of payment stablecoins) and Item
2 (Top 100 payment stablecoin wallet addresses by trading volume) from
proposed Schedule A have been moved to revised Schedule A, with
modifications, and Item 5 (Top five counterparties by exposure) from
proposed Schedule A has been moved to revised Schedule B. Item 3 (Top
100 exchanges by trading volume) and Item 4 (Daily total trading volume
of all exchanges) from proposed Schedule A have been removed from Form
PS-01 entirely. These categories of information were eliminated because
they overlap with other categories of information that the OCC is
proposing to collect, have limited supervisory utility, and would be
unnecessarily burdensome to collect.
Proposed Schedule B--Issuance and Redemption
Proposed Schedule B would collect information on the issuance and
redemption of stablecoins over the reporting period, as well as
information on secondary market price and trading activity.
The OCC received numerous comments concerning proposed Schedule B
and the information the OCC proposed to be collected. One commenter
strongly urged the OCC to revisit Schedule B's secondary market price
and trading activity requirements to ensure issuers are not required to
report data they cannot reasonably generate or verify themselves.
Another commenter expressed support for anchoring Schedule B to
primary-market issuance and redemption data, which is information a
permitted payment stablecoin issuer controls and can reliably report.
The commenter also claimed that this information is the most probative
measure of reserve, liquidity, and redemption risk. The commenter
further stated that permitted payment stablecoin issuers should not be
required to certify secondary-market activity beyond information they
can
[[Page 66925]]
reasonably obtain, standardize, and validate. The commenter also
expressed support for treating every transaction in which a customer
provides fiat and receives stablecoins as issuance, and every
transaction in which a customer provides stablecoins and receives fiat
as redemption, regardless of whether the transaction involves the
technical minting or burning of tokens. The commenter also expressed
support for separate treasury-stablecoin line items as a market-
integrity control but stated that those fields should be reported
quarterly rather than weekly.
One commenter recommended incorporating additional distributional
and stress-sensitive measures, including pending, rejected, and
partially fulfilled redemption requests; major redemption
counterparties; median and tail redemption times; redemptions exceeding
contractual timelines; and redemption activity by direct customers,
intermediaries, affiliates, and unaffiliated parties. The commenter
explained that these metrics would help the OCC determine whether
redemption stress is concentrated among particular counterparties,
channels, or market structures.
Another commenter stated that the concentration of the reporting
permitted payment stablecoins issuer's issuance and redemption traffic
among the counterparties through which it passes, a measure closely
connected to redemption pressure, is absent from Schedule B. The
commenter claimed that every permitted payment stablecoin issuer knows
this with precision from its own transaction records. Another commenter
stated that Form PS-01 should distinguish direct redemptions from
redemptions submitted through intermediaries, as well as redemptions by
affiliates, market makers, and other significant counterparties. The
commenter claimed that this disaggregation would help the OCC better
understand how redemption pressure reaches the issuer and whether
reliance on intermediaries, exchanges, or arbitrageurs could affect
redemption activity during periods of market stress.
Several commenters requested clarification of certain aspects of
Schedule B. One commenter stated that columns under Item 1.a
(Blockchain name) include several reporting fields with ambiguous
descriptions that would benefit from clarification. Specifically, the
commenter explained that the distinction between Column C (Payment
stablecoins redeemed) and Column D (Payment stablecoins removed from
circulation) is not clear. The commenter also stated that the
definition of time-locked stablecoins in Column F (Time-locked) also
has room for various interpretations.
Another commenter requested that the OCC: (i) specify that Item 2.e
(Secondary-market bid/ask spread) is computed across centralized venues
only, or in the alternative specify a defined proxy methodology for
automated market maker venues; (ii) specify the computation methodology
for items 2.c (Estimated secondary-market price) and 2.d (Estimated
secondary-market peg deviation) across mixed venue populations; and
(iii) confirm that a reporting issuer may report Items 2.a through 2.e
from a named third-party market data source.
Another commenter stated that the OCC should also clarify how
nonrepresentative trades are treated when calculating minimum price,
maximum price, Volume-Weighted Average Price (``VWAP''), peg deviation,
and bid/ask spread metrics. The commenter explained that small, stale,
infrequent, outlier, wash, or affiliated trades may distort reported
secondary-market conditions if not treated consistently. The commenter
added that without clear standards governing the treatment of such
transactions, reported pricing metrics may not accurately reflect
prevailing market conditions or issuer-specific stress.
Another commenter observed that proposed Schedule B would require
reporting on ``Outstanding issuance value at beginning of day'' and
``Outstanding issuance value at end of day'' and recommended that the
reporting template be updated to show how the beginning of day and end
of day balances would be reported for each day of the reporting week.
Another commenter encouraged the OCC to adopt limitations on trade
reporting to ensure permitted payment stablecoin issuers and foreign
payment stablecoin issuers report only information that provides
meaningful supervisory value. The commenter suggested excluding small
transactions and those that do not reflect prevailing market terms,
such as trades lacking sufficient volume, frequency, or recency. The
commenter claimed that this approach would better focus Schedule B
reporting on the information most relevant to monitoring issuer
liquidity, potential redemption stress, and secondary-market price
stability.
Revised Schedule A
As discussed above, the OCC has consolidated certain items from
proposed Schedule A with proposed Schedule B. As a result, the
consolidated Schedule A and Schedule B has been re-classified as
revised Schedule A. The OCC has also implemented numerous changes to
revised Schedule A to reduce the reporting burden, address comments,
clarify categories of information and their corresponding instructions,
and improve the presentation and technical accuracy of certain
calculations.
Item 1.a (Digital Ledger Identifier (DLI)) has been amended to
allow a permitted payment stablecoin issuer to report, if available,
the DLI for the blockchain network.
Revisions were made to proposed Columns A through I to clarify the
calculation of daily changes in outstanding issuance value.
Calculations on daily changes in outstanding issuance value are
preserved, and simplified, in revised Columns A through F, while also
preserving supporting information in revised Columns K and L that were
reported in proposed Columns E through H.
Item 1.a of revised Schedule A has been amended to reflect the
addition of Columns H (Payment stablecoins redeemed through non-reserve
assets), I (Other payment stablecoin redemption), J (Payment
stablecoins held in issuer-controlled wallets), and K (Temporarily
nonredeemable payment stablecoins).
Column A now requests the blockchain's name instead of the
outstanding issuance value at the beginning of the day, which has been
moved to Column B.
Revised Column B has been further amended to clarify that
``outstanding issuance value'' is meant as that term is defined in
section 15.2.
Revised Column C now requests information on the number of payment
stablecoins issued during a calendar day. The instructions now clarify
that ``payment stablecoins'' is meant as that term is defined in
section 15.2. The amended instructions for Column C also remove the
reference to ``on each specific blockchain'' from the first sentence
because it is redundant based on the reporting structure of revised
Schedule A. The instructions for Column C also remove the direction to
omit Treasury stablecoins because the instructions now clarify that
payment stablecoins reported in this column must meet the definition of
a payment stablecoin in section 15.2.
Revised Column D now requires permitted payment stablecoin issuers
to include information about the payment stablecoins redeemed during a
calendar day. The instructions have been amended to further clarify
that ``redemption'' is meant as that term is defined in section
15.12(a)(2). Specifically, redemption is deemed to
[[Page 66926]]
occur when a permitted payment stablecoin issuer has fully processed
and initiated the outgoing transfer of funds to the customer or the
customer's financial institution as directed by the customer, or, if
requested by the customer, credited funds to the customer's account
with the permitted payment stablecoin issuer. Revised Column D includes
information that would have been reported in proposed Columns C and D
of proposed Schedule B.
Revised Column E has been amended by replacing the requirement to
report payment stablecoins removed from circulation with a requirement
to report other changes to the outstanding issuance value. The
instructions have been clarified to explain that permitted payment
stablecoin issuers should use this column to report the total par value
of payment stablecoins added to or removed from the outstanding
issuance value balance unrelated to payment stablecoin issuance or
redemption. Revised column E is necessary to accurately calculate daily
changes in outstanding issuance value that would not be captured in
revised Columns B and C.
Revised Column F now collects the total outstanding issuance value
at the end of each calendar day (i.e., as of 11:59:59 p.m. (Eastern)).
As the instructions explain, this field will automatically be populated
based on the inputs in Columns B, C, D, and E.
Columns G through I were added to report similar information to
proposed Columns C and D, with additional clarity in instructions and a
new data item in Column I needed to reconcile the detail information on
daily redemptions to total daily redemptions.
Revised Column G requires permitted payment stablecoin issuers to
report the daily total of payment stablecoins redeemed where the source
of funds is directly from reserve assets and the payment stablecoin is
simultaneously burned.
Revised Column H now requires permitted payment stablecoin issuers
to report the daily total value of all payment stablecoins redeemed
where the source of funds are not reserve assets and the payment
stablecoin remains outstanding and is not burned.
Revised Column I requires permitted payment stablecoin issuers to
report the total payment stablecoins that were redeemed, but not
reported in either Column G (Payment stablecoins redeemed through
reserve assets) or Column H (Payment stablecoins redeemed through non-
reserve assets).
Column J requires permitted payment stablecoin issuers to report
all payment stablecoins held in issuer-controlled wallets, commonly
known as ``Treasury,'' ``corporate held,'' or ``minted but not issued''
stablecoins.
Column K requires permitted payment stablecoin issuers to report
all temporarily nonredeemable payment stablecoins, including, but not
limited to temporary access restricted and time-locked stablecoins. The
instructions define ``temporary access-restricted payment stablecoins''
to mean those payment stablecoins that are currently held in wallets or
smart contracts subject to temporary freezes or administrative blocks
(e.g., blacklist functions). The instructions further define ``time-
locked payment stablecoins'' to mean payment stablecoin on each
specified blockchain that are held in issuer-imposed smart contracts or
vesting schedules that are solely controlled by the issuer, and that
prevent transfer or liquidation until a specific future timestamp or
block height. The instructions also explain that a permitted payment
stablecoin issuer should also report here any other payment stablecoin
that is temporarily nonredeemable where the payment stablecoin was
fully funded by a customer when issued and has not been redeemed.
Column K now combines Columns E (Temporary access-restricted) and
Column F (Time-locked) from proposed Schedule B.
Column L requires permitted payment stablecoin issuers to report
the end-of-day total of payment stablecoins that have been issued but
not redeemed and are irretrievably lost or inaccessible and not subject
to redemption by contractual or other means.
Item 1.b (Total payment stablecoins) of revised Schedule A has been
amended to replace ``Blockchain name'' with ``Digital Ledger
Identifier.'' As discussed above, this change was implemented to
improve the accuracy of the information the OCC collects about the
blockchain a payment stablecoin operates on.
Item 2 (Secondary market pricing) of revised Schedule A covers
secondary market pricing data. Items 2.a through 2.e replace the phrase
``listed on Schedule A.3'' with ``on which the payment stablecoin is
traded.'' This change was implemented to reflect that the OCC is
eliminating proposed Item 3 from proposed Schedule A (Top 100 exchanges
by trading volume) from Form PS-01.
The instructions for Item 2.e (Secondary-market bid/ask spread)
also now clarifies that a permitted payment stablecoin issuer should
exclude from the bid-ask spread calculation, any exchange for which
end-of-day bid or ask prices are unavailable or for which a bid-ask
spread is not applicable or cannot be reasonably calculated based on
the exchange's market structure.
Item 3 (Liquidity measures) of revised Schedule A requires
permitted payment stablecoin issuers to report information related to
liquidity measures. Item 3.a has been changed to ``Total payment
stablecoins purchased not yet issued'' from ``Total payment stablecoins
purchased not yet minted.'' The instructions further clarify that the
OCC is seeking information about the aggregate count of payment
stablecoins for which valid purchase orders have been received and
funds cleared, but for which the corresponding on-chain issuance--not
minting--transaction has not been finalized. These changes were
implemented to clarify that the OCC is seeking information about
payment stablecoins that have been purchased--minted or not--but not
issued.
Item 3.c (Average redemption time) has been amended to clarify that
permitted payment stablecoin issuers should comply with section
15.12(a) and (b) for purposes of determining confirmation of a
redemption request and when a transfer to a payment stablecoin holder
is initiated.
Item 3.d has been changed to ``Total redemption dollar amount
exceeding two business days'' from ``Total redemption dollar amount
exceeding 48 hours.'' This change was implemented to align with section
15.12(c)(1), which requires a permitted payment stablecoin issuer's
redemption policy to state that timely redemption may not exceed two
business days following the date of the requested redemption.
Item 5 (Top 20 redemptions) was added to revised Schedule A and
requires permitted payment stablecoin issuers to report additional
information related to redemptions in addition to Items 4.a through
4.c. Specifically, Item 5 requires permitted payment stablecoin issuers
to report the 20 wallet addresses with the largest cumulative amount of
redemption transactions successfully processed each reporting day. The
addresses and the accompanying transaction amounts will be reported
under Item 5.a. This information is a modification of the data
requested in proposed Schedule A, Item 2 (Top 100 payment stablecoin
wallet addresses by trading volume). The OCC is requesting this
information in response to comments concerning burden, whether the
issuer has access to or control over third parties and to better align
with supervisory needs. Permitted payment stablecoin issuers will have
ready access to verifiable information on redemptions, compared to
transaction
[[Page 66927]]
activity by wallet addresses that may have no relationship to the
issuer. The number of addresses was reduced from 100 to 20 to reduce
the reporting burden. The OCC believes it is important to collect this
information because redemptions are directly related to a permitted
payment stablecoin issuer's liquidity risk and will allow the OCC to
monitor and assess trends and concentration in redemption activity in
normal and stress environments.
Finally, the OCC has incorporated Item 1 (Top 100 payment
stablecoin wallet addresses by number of payment stablecoins) from
proposed Schedule A into revised Schedule A as Item 6. However, instead
of seeking the top 100 payment stablecoin wallets by number of payment
stablecoins, Item 6 asks permitted payment stablecoin issuers to report
all wallets that hold more than two percent of the total outstanding
payment stablecoins as of the end of each day. Item 6.a now requires
permitted payment stablecoin issuers to report the addresses and
corresponding payment stablecoin holdings as of the end of each day.
The OCC is implementing this change to ensure that the information
concerning concentration risk being collected is relevant to the
supervision of permitted payment stablecoin issuers. A few commenters
recommended implementing a size threshold to avoid forcing permitted
payment stablecoin issuers to report wallet addresses with payment
stablecoin holdings that are inconsequential and thus lack relevance to
the supervision of a permitted payment stablecoin issuer. The OCC is
also implementing this change to indirectly cap the total number of
wallets that a permitted payment stablecoin issuer would need to report
at 50.
Description of Revised Schedule A
In summary, revised Schedule A collects similar information on the
issuance and redemption of stablecoins over the reporting period,
information on secondary market price and trading activity, liquidity
measures, and concentration metrics as proposed Schedule B.
Schedule C--Reserve Assets
Proposed Schedule C would collect information on the reserve assets
used to back the outstanding issuance of a stablecoin issued by a
permitted payment stablecoin issuer. This information would include a
list of all reserve assets by type, as well as information on each
class of reserve assets, including fair value and amortized cost.
Schedule C would collect, among other information, the balance of
assets within each asset category that are in tokenized form.
The OCC received numerous comments concerning proposed Schedule C
and the information proposed to be collected. One commenter stated that
reserve reporting should improve supervisory visibility without
narrowing the statutory reserve criteria. The commenter added that fair
value is the appropriate uniform measure for reserve sufficiency
because it best reflects whether reserve assets support the at-all-
times 1:1 backing requirement.\21\ The commenter further added that
reporting fields should not impose a de facto weighted-average-maturity
cap or create special limits for off-the-run Treasury securities.
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\21\ See 12 U.S.C. 5903(a)(1)(A).
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Another commenter observed that FDIC PS-01a would collect a weekly
minimum, maximum and average reserve asset coverage ratio (i.e.,
reserve assets against outstanding issuance), but this ratio does not
appear on Form PS-01, although it is derivable from data both full
forms already collect. The commenter claimed that collecting this
information would enhance the utility of the information collected at
negligible additional burden and would place the most direct indicator
of reserve adequacy on the face of the form.
In the notice, the OCC invited comments on whether additional
information about tokenized assets should be included elsewhere in the
reporting form, for example, specific items on tokenized deposits or
tokenized money market funds. One commenter stated that the reporting
fields should not treat tokenized forms of otherwise eligible reserve
assets as separate asset classes and the final instructions should make
clear that tokenized forms of otherwise eligible reserve assets are
reportable within the corresponding underlying category. Another
commenter stated that the OCC should adopt a technology-neutral
approach with respect to reporting reserve assets. The commenter
claimed that reporting reserve assets should not depend upon the
technology or recordkeeping used to record those assets; if a tokenized
U.S. Treasury security and a non-tokenized U.S. Treasury security are
both held as reserve assets and represent the same claim on the U.S.
government, their distinction for reserve adequacy purposes appears
immaterial.
Revised Schedule B
As discussed above, the OCC has consolidated proposed Schedule A
and Schedule B in Form PS-01. As a result, proposed Schedule C has been
re-classified as the revised Schedule B.
Items 1 and 1.a through 1.f remain unchanged from proposed Schedule
B. The OCC has revised Item 1.g (Total reserve assets) by adding
``before considering liabilities on repurchase agreements'' to the end
of the last sentence. The OCC added this language to clarify that the
reported figure in 1.g is meant to identify the total reserve assets
available to support the outstanding payment stablecoins net of
repurchase agreement liabilities.
Item 1.h (Outstanding repurchase agreement liabilities) adds a new
information collection for outstanding repurchase agreement
liabilities. This item was moved from proposed Schedule D, Item 1.c,
Column E (Repurchase Agreement Liabilities) to ensure accurate
calculation of Column B and provide additional clarity on Reserve asset
value. As proposed, Column B would not have resulted in accurate
calculations because the underlying formula relied upon gross reserve
assets, not reserve assets net of repurchase agreement liabilities.
Reserve assets net of repurchase agreement liabilities also aligns with
the regulatory definition of Reserve asset value in section 15.2.\22\
Moving this item from proposed Schedule D improves clarity by
consolidating all components of Reserve asset value on the same
schedule. Permitted payment stablecoin issuers must report the dollar
amount of repurchase agreement liabilities related to money received
from repurchase agreements that are held as reserve assets.
---------------------------------------------------------------------------
\22\ See 12 CFR 15.2, which states that the ``Reserve asset
value of a payment stablecoin means the sum of: (1) The total fair
value of reserve assets, net of any associated liabilities, other
than United States coins and currency; and (2) The total face value
of reserve assets comprising United States coins and currency.''
---------------------------------------------------------------------------
Item 2 adds a new information collection for total reserve assets
net of outstanding repurchase agreement liabilities. This reported
figure is derived from Item 1.g (Total reserve assets) less Item 1.h
(Outstanding repurchase agreement liabilities). This figure represents
the total Reserve asset value held to support outstanding issuance
value. Also, under Item h, the OCC has amended the instructions for
Column B by changing ``1.g'' to ``2'' to reflect that the denominator
in the calculation is now the total reserve assets net of outstanding
repurchase agreement liabilities and not total reserve assets.
Items 5 (Top five counterparties by exposure) and 5.a (Non-Federal
Reserve
[[Page 66928]]
Bank counterparty names) were removed from proposed Schedule A and
relocated in revised Schedule B as Items 3 and 3.a. These categories of
information remain unchanged from proposed Schedule A. The OCC is also
adding a new category of information, Reserve Asset Withdrawals, as
Item 4 in revised Schedule B. The OCC proposed collecting information
about reserve asset withdrawals through proposed Schedule E of proposed
Form PS-02 but did not propose collecting this information in proposed
Form PS-01. Upon additional review, the OCC believes collecting
information weekly about withdrawals from reserve assets serves a
valuable supervisory purpose. Any reduction in reserve assets without a
corresponding change in outstanding issuance value reduces reserve
asset coverage for payment stablecoin holders. Reporting this
information allows the OCC to monitor and assess changes to reserve
asset coverage, including potentially changes to a permitted payment
stablecoin issuer's risk tolerance (i.e., reducing reserve asset
coverage). This information also helps reconcile daily changes in
reserve assets. Thus, the OCC has included this category of information
in revised Schedule B.
Description of Revised Schedule B
In summary, revised Schedule B would now collect information on the
reserve assets used to back the outstanding issuance of a stablecoin
issued by a permitted payment stablecoin issuer. This information would
include a list of all reserve assets by type, as well as information on
each class of reserve assets, including fair value and amortized cost.
Revised Schedule B would also collect information about counterparty
exposure and reserve asset withdrawals.
Schedule D--Cash Balances Schedule D
Proposed Schedule D would collect information on cash balances held
as reserve assets. This information would include items on the location
and size of insured and uninsured deposits maintained at depository
institutions, as well as any balances maintained at a Federal Reserve
Bank. Proposed Schedule D would also collect aggregate information on
repurchase agreement transactions and associated liabilities. Proposed
Schedule D includes line items for cash balances held at U.S.
depository institutions and foreign depository institutions.
In the notice, the OCC invited comment on the proper handling of
U.S. and foreign cash balances, as well as whether there should be
other distinctions among cash balances serving as payment stablecoin
reserves. One commenter expressed support for reporting cash reserves
by location and size, including balances maintained at Federal Reserve
Banks and at U.S. and foreign depository institutions, provided that
this information remains confidential and supervisory-only. The
commenter added that the reporting instructions should reflect the
GENIUS Act's express recognition that reserve assets may include demand
deposits at foreign branches, agents, and correspondent banks of U.S.
insured depository institutions under Sec. 4(a)(1)(A)(ii).\23\ The
commenter added that the reporting form should capture lawful reserve
activity; it should not be designed in a way that presupposes or
effectively imposes a U.S.-only reserve-location requirement that is
left explicitly open in the GENIUS Act.
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\23\ See 12 U.S.C. 5903(a)(1)(A)(ii).
---------------------------------------------------------------------------
The OCC disagrees that the instructions for proposed Schedule D
require revisions to explicitly state which cash balances are
permissible reserve assets. The GENIUS Act and the final rule identify
the suite of reserve assets, including cash balances, that a permitted
payment stablecoin issuer may hold.
Another commenter stated that proposed Schedule D only requests
aggregate deposits in U.S. and foreign depository institutions. The
commenter further claimed that uninsured deposits represent the highest
credit risk in reserve assets.
In response to this comment, as discussed below, the OCC has
incorporated institution-level reporting into the revised schedule.
Revised Schedule C
As discussed above, the OCC has consolidated proposed Schedule A
and Schedule B in Form PS-01. As a result, proposed Schedule D has been
re-classified as the revised Schedule C.
Item 1 of proposed Schedule D required permitted payment stablecoin
issuers to, ``Report cash balances disaggregated by the following
categories.'' The OCC has removed this item from revised Schedule C.
Item 1 in revised Schedule C now states, ``U.S. depository
institutions.'' Under this item, permitted payment issuers must provide
reporting on the cash balances held in U.S. depository institutions.
Item 1.a of revised Schedule C also includes a new column requesting
that permitted payment stablecoin issuers provide the RSSD ID for each
financial institution. This change is being incorporated in response to
a comment concerning the risk associated with uninsured cash deposits.
This reporting will provide the OCC with relevant detail about the
institutions holding reserve assets as cash deposits as well as
institution-level detail about uninsured deposits.
Column A (Total cash balances), Column B (Insured balances), and
Column C (Uninsured balances) of Item 1.a mirror the categories of
information in proposed Scheduled D. However, the instructions for
Columns B and C of revised Schedule C have been modified to clarify
that insured and uninsured cash balances should be reported for each
institution. Column D (Money received under repurchase agreements) was
also removed from revised Form PS-01. As discussed above, Column E
(Repurchase agreement liabilities) and Column F (Money received under
repurchase agreements net of repurchase agreement liabilities) were
moved to revised Schedule B for organizational purposes and to enhance
reporting related to reserve assets and repurchase agreement
liabilities associated with reserve assets. Revised Schedule C now also
includes a new Column D which requires a permitted payment stablecoin
issuer to indicate whether any of its cash balances held at U.S. or
foreign depository institutions are held as tokenized deposits. The OCC
believes that understanding whether cash balances are held as
traditional fiat deposits or as tokenized deposits is important because
there may be operational or liquidity differences in tokenized and non-
tokenized reserve assets.
Items 2 and 2.a of revised Schedule C replicate the information
collection under Items 1 and 1.a, except that the information requested
relates to cash balances held in foreign depository institutions. Item
1.c (Federal Reserve Bank deposits) in proposed Schedule D has been
moved and re-classified as Item 3 in revised Schedule C. In addition,
the OCC has included instructions for Item 3 explaining that a
permitted payment stablecoin issuer should report the dollar amount of
money standing to the credit of an account with a Federal Reserve Bank.
Description of Revised Schedule C
In summary, revised Schedule C would now collect information on
cash balances held as reserve assets. This information would include
items on the location and size of insured and uninsured deposits
maintained at depository institutions, as well as any balances
maintained at a Federal Reserve Bank.
[[Page 66929]]
Schedule E--U.S. Treasury Securities
Proposed Schedule E would collect information on U.S. Treasury
securities held as reserve assets. This information would include the
Committee on Uniform Securities Identification Procedures (``CUSIP'')
numbers for U.S. Treasury securities, their fair value, remaining
maturity, coupon rate, effective interest rate, and information about
the custodian holding the securities, as well as information, such as
counterparty and collateral haircut, on any U.S. Treasury securities
encumbered by outstanding repurchase agreements.
The OCC received several comments related to proposed Schedule E.
One commenter expressed support for confidential supervisory reporting
of issuer-maintained Treasury-security data. However, the commenter
claimed that the proposed sub-24-hour reporting turnaround, combined
with a requirement to produce daily individual security positions,
counterparty names, and collateral breakdowns, presents a significant
operational challenge. The commenter further claimed that standard
treasury and custody platforms are built to record aggregate holdings,
fund-level balances, and total counterparty exposures and not the
instrument-level and counterparty-level detail proposed Form PS-01
seeks on a continuous daily basis. The commenter added that meeting
this requirement would necessitate purpose-built data extraction and
reconciliation workflows that go well beyond the capabilities of
existing back-office infrastructure. The commenter also stated that the
OCC should define maturity fields on a remaining-maturity basis
consistent with the GENIUS Act's 93-days-or-less standard for Treasury
bills, notes, and bonds. The commenter added that the reporting form
should not impose, or imply, a separate weighted-average-maturity cap
or other maturity constraint that narrows the statutory reserve asset
basket.
Another commenter observed that proposed Schedule E would collect
information on U.S. Treasury securities held as reserve assets,
including the CUSIP numbers for individual U.S. Treasury securities.
The commenter stated that CUSIP information for U.S. Treasury
securities is more granular than it is for money market mutual funds
and would impose substantial burden on permitted payment stablecoin
issuers. The commenter further recommended that the OCC consider
collecting aggregated U.S. Treasury security information (e.g.,
bucketed by maturity) that would provide the necessary supervisory
information without the associated burden of CUSIP-level reporting.
First, as discussed above, the OCC has modified the reporting
instructions for Form PS-01 to provide for an additional 24 hours to
prepare and file Form PS-01. Second, due to permitted payment
stablecoin issuers' sensitivity to interest rate risk, it is essential
that the OCC have timely and accurate data concerning a permitted
payment stablecoin issuer's interest rate risk profile. The information
proposed to be collected will provide the OCC with the necessary data
to ascertain a permitted payment stablecoin issuer's interest rate
risk. Finally, the OCC is retaining CUSIP-level reporting because
Treasuries likely represent the largest source of interest rate risk
for permitted payment stablecoin issuers. Given this, the OCC believes
CUSIP-level reporting is necessary to accurately account for a
permitted payment stablecoin issuer's interest rate risk.
Revised Schedule D
As discussed above, the OCC has consolidated proposed Schedule A
and Schedule B in Form PS-01. As a result, proposed Schedule E has been
re-classified as the revised Schedule D.
The OCC is making minimal revisions to information collection in
proposed Schedule E. However, for Items 1.a (CUSIP) and 3.a (Repurchase
agreement collateral CUSIP), the OCC has added Columns L and I,
respectively, to collect information related to whether the listed
security is tokenized. The OCC believes that understanding whether
reserve assets are held in tokenized or non-tokenized form is important
because there may be operational, market, or liquidity differences in
tokenized and non-tokenized reserve assets. Otherwise, the OCC has not
proposed any additional revisions to revised Schedule D.
Description of Revised Schedule D
Revised Schedule D would collect information on U.S. Treasury
securities held as reserve assets. This information would include the
CUSIP numbers for individual U.S. Treasury securities, their fair
value, remaining maturity, coupon rate, effective interest rate,
tokenization, and information about the custodian holding the
securities, as well as information, such as counterparty and collateral
haircut, on any U.S. Treasury securities encumbered by outstanding
repurchase agreements.
Schedule F--Reverse Repurchase Agreements
Proposed Schedule F would collect information on reverse repurchase
agreement transactions held as reserve assets. This would include
information on the repurchase agreements including counterparty, cash
lent, agreement type and name of agent. Proposed Schedule F would also
collect information on securities collateralizing the reverse
repurchase transaction, such as collateral values, collateral maturity,
collateral haircuts, days until maturity or interest rate reset, and
whether rehypothecation is allowed.
The OCC did not reserve any comments concerning proposed Schedule
F.
Revised Schedule E
As discussed above, the OCC has consolidated proposed Schedule A
and Schedule B in Form PS-01. As a result, proposed Schedule F has been
re-classified as the revised Schedule E.
The OCC is making minimal revisions to the information collection
in proposed Schedule F. However, for Item 2.a (Reverse repurchase
agreement collateral CUSIP), the OCC has added Column I to collect
information related to whether the listed security is tokenized.
Description of Revised Schedule E
Revised Schedule E would collect information on reverse repurchase
agreement transactions held as reserve assets. This would include
information on the repurchase agreements including counterparty, cash
lent, agreement type and name of agent. Revised Schedule E would also
collect information on securities collateralizing the reverse
repurchase transaction, such as collateral values, collateral maturity,
collateral haircuts, days until maturity or interest rate reset, and
whether rehypothecation is allowed.
Schedule G--Money Market Mutual Funds
Proposed Schedule G would collect information on money market
mutual funds held as reserve assets, including fund name and sponsor,
CUSIP, net asset value (``NAV''), and effective interest rate, WAM, WAL
as well as information on custodians.
The OCC received several comments related to proposed Schedule G.
One commenter expressed support for confidential supervisory reporting
of issuer-maintained money market fund data--including fund name,
sponsor, CUSIP, NAV, and custodian. However, the commenter added that
requiring a daily effective interest rate is not
[[Page 66930]]
feasible because interest on money market fund holdings accrues and is
reported on a monthly cycle, making daily rate calculation
operationally inconsistent with how these instruments are administered
and recorded. The commenter stated that the instructions should clarify
that eligible reserve assets in this category are limited to Government
money market funds that maintain a stable $1.00 NAV and whose
underlying assets remain within the GENIUS Act's reserve-asset
perimeter and prime and municipal money market funds should not be
treated as eligible reserve assets. The commenter also recommended that
the OCC require a single, clearly defined maturity measure rather than
both WAM and WAL. The commenter stated that given the short-duration,
high-liquidity nature of eligible Government money market funds,
requiring both measures would add a duplicative reporting burden
without materially improving supervisory insight.
The OCC declines to make changes to WAL and WAM reporting, as both
measures are required to be calculated and reported by money market
mutual funds.\24\
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\24\ See 17 CFR 270.2a-7(d).
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Another commenter stated that the percentage ownership field for
money market mutual funds in proposed Schedule G should be replaced
with a field measuring either the fair value or NAV-based value of the
permitted payment stablecoin issuer's holdings in the fund. The
commenter added that calculating the permitted payment stablecoin
issuer's percentage ownership of the fund will require external data
that may not be available to a permitted payment stablecoin issuer on
the required reporting cadence, and so completing the form may require
a permitted payment stablecoin issuer to engage with external vendors
to source necessary information.
As discussed below, the OCC is revising the schedule to only
require a permitted payment stablecoin issuer to indicate if the
permitted payment stablecoin issuer holds more than 50% of a money
market mutual fund.
Revised Schedule F
As discussed above, the OCC has consolidated proposed Schedule A
and Schedule B in Form PS-01. As a result, proposed Schedule G has been
re-classified as the revised Schedule F.
The OCC has added a new Item 1, Money Market Mutual Funds, with
accompanying instructions that a permitted payment stablecoin issuer is
required to report information related to money market mutual funds
held as reserve assets. As result of this addition, Item 1 in proposed
Schedule G (Fund name) has been reclassified as Item 1.a in revised
Schedule F. Under Item 1.a., the OCC has made several amendments to the
instructions for Columns A, C, D, and E and added a new Column J. Under
proposed Schedule G, Column A would require a permitted payment
stablecoin issuer to report the percentage ownership of a money market
mutual fund. A commenter explained that it could be operationally
challenging to determine the ownership percentage of a fund due to
certain informational challenges, including the mismatch between the
reporting cadence for money market mutual funds and the weekly
reporting requirements. In response to this comment, the OCC has
modified this information collection to only require a permitted
payment stablecoin issuer to indicate if the permitted payment
stablecoin issuers owns more than 50% of the money market mutual fund.
The OCC believes that these changes to the information collection will
alleviate some of the operational concerns commenters raised while also
ensuring that the OCC has timely information concerning significant
reserve asset concentrations.
The OCC is modifying Column C to collect the LEI of the money
market mutual fund instead of its ticker. The OCC is requesting
permitted payment stablecoin issuers report the LEI of its money market
mutual funds instead of tickers to increase the accuracy of the
information reported and minimize the potential for confusion that
could arise through the use of ticker symbols.
The OCC is making clarifying modifications to Column D (Weighted
average maturity (WAM)). Specifically, the OCC is amending the
instructions for Column D to clarify that WAM is defined as the dollar-
weighted average time remaining, measured in days, based on the
percentage of each security's market value in the money market mutual
fund. This change was implemented to clarify that the OCC is seeking
the weighted average of the underlying securities and not the money
market mutual fund. The instructions further clarify that for floating
rate securities in the money market mutual fund, the maturity shall be
deemed one day. Finally, the instructions clarify that if the WAM is
unavailable as of the reporting date, a permitted payment stablecoin
issuer should report the most recent WAM available. Similarly, the OCC
is modifying the instructions for Column E (Weighted average life
(WAL)) to clarify that, if the WAL is unavailable as of the reporting
date, a permitted payment stablecoin issuer should report the most
recent WAL available.
Finally, the OCC is adding Column J to revised Schedule F to
collect information related to whether the reported money market fund
is tokenized.
Description of Revised Schedule F
Revised Schedule G would collect information on money market mutual
funds held as reserve assets, including fund name and sponsor, CUSIP,
NAV, and effective interest rate, WAM, WAL as well as information on
custodians.
Schedule H--Other Instruments
Proposed Schedule H would collect information on any other
instruments held as reserve assets. While the information collected by
the other schedules would likely cover all reserve assets, Schedule H
would act as a catch-all collection information on any reserve assets
otherwise not covered by the other schedules, for example for any
physical currency held by a permitted payment stablecoin issuer.
The OCC received one comment related to proposed Schedule H.
Specifically, one commenter stated that the instructions should treat
Schedule H as an exception-based reporting field, and not an invitation
to create new reserve categories or commingle alternative crypto-assets
or other non-GENIUS Act assets with the payment stablecoin reserve.
As stated above, the intent of proposed Schedule H is to act as a
catch-all collection of information to ensure that all reserve assets
are reported. The inclusion of the schedule is not an invitation to
permitted payment stablecoin issuers to use impermissible assets as
reserve assets. The GENIUS Act and the final rule are clear about the
universe of permissible reserve assets.\25\
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\25\ See 12 U.S.C. 5903(a)(1)(A) and 12 CFR 15.11.
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Revised Schedule G
As discussed above, the OCC has consolidated proposed Schedule A
and Schedule B in Form PS-01. As a result, proposed Schedule H has been
re-classified as the revised Schedule G.
The OCC is making minimal revisions to the information collection
in proposed Schedule H. However, the OCC has added a new Item 1, Other
Instruments, with accompanying instructions that a permitted payment
stablecoin issuer is required to report information related to other
instruments held as reserve assets. As result of this addition, Item 1
in proposed Schedule
[[Page 66931]]
H (Instrument name) has been reclassified as Item 1.a in revised
Schedule G. Under Item 1.a, the OCC has also added a new Column F to
collect information related to whether any other instruments reported
are tokenized.
Description of Revised Schedule G
Revised Schedule G would collect information on any other
instruments held as reserve assets. While the information collected by
the other schedules would likely cover all reserve assets, revised
Schedule G would act as a catch-all collection information on any
reserve assets otherwise not covered by the other schedules (e.g., any
physical currency held by a permitted payment stablecoin issuer).
Quarterly Reporting Form PS-02
The proposed quarterly reports of financial condition for permitted
payment stablecoin issuers and foreign payment stablecoin issuers
required by sections 15.14(i) and 15.31(b)(2) mirrors the quarterly
statements of financial condition that national banks and Federal
savings associations provide to the Federal banking agencies through
their quarterly Call Reports.\26\ The information required to be
reported quarterly will be streamlined substantially relative to the
Call Reports, in light of the comparatively simple business model of a
permitted payment stablecoin issuer. Standardizing these reporting
requirements will enhance the OCC's ability to supervise permitted
payment stablecoin issuers and foreign payment stablecoin issuers and
provide clarity as to the information a permitted payment stablecoin
issuer or foreign payment stablecoin issuer must report. Some OCC-
regulated institutions may already be subject to other reporting
obligations, notably the Call Report.
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\26\ See 12 U.S.C. 161(a) (requiring national banks to make
reports of condition to the OCC); and 12 U.S.C. 1464(v) (requiring
Federal savings associations to make reports of condition to the
OCC).
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Proposed Schedule A would collect an income statement from the
permitted payment stablecoin issuer or foreign payment stablecoin
issuer. Proposed Schedule B would collect a balance sheet from the
permitted payment stablecoin issuer or foreign payment stablecoin
issuer. Proposed Schedule C would collect information about off-balance
sheet items from the permitted payment stablecoin issuer or foreign
payment stablecoin issuer. Proposed Schedule D would collect additional
information about capital elements and operational backstop from the
permitted payment stablecoin issuer based on the capital requirements
in the proposed rule.\27\ Proposed Schedule E would collect additional
information about a permitted payment stablecoin issuer's or foreign
payment stablecoin issuer's operations including information about
reserve assets, other assets and liabilities, number of branded
stablecoins issued, stablecoin issuances, redemption, burn data,
blockchains, redemption metrics, and custody activities. The OCC
intends to publish the information provided in the quarterly report to
ensure transparency and that the public understands a permitted payment
stablecoin issuer's or a foreign payment stablecoin issuer's financial
condition on an ongoing basis.
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\27\ Foreign payment stablecoin issuers would not be required to
complete Schedule D as foreign payment stablecoin issuers would not
be subject to the capital requirements in Subpart E of the proposed
rule.
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As a part of the notice, the OCC invited comments on what items
should be modified or removed, as well as whether any items should be
added. A few commenters expressed their views on a range of issues
related to proposed Form PS-02, its instructions, the overall reporting
structure, and reporting requirements.
Several commenters provided feedback on the requirement to file
Form PS-02 and others proposed alternative reporting structures. One
commenter stated that the OCC should allow permitted payment stablecoin
issuers to satisfy their quarterly reporting obligations through a
single report. The commenter stated that OCC-regulated institutions
that file a Call Report should be exempt from Form PS-02 reporting. The
commenter further stated that a permitted payment stablecoin issuer
should be allowed to submit only the Call Report and Form PS-01 to
satisfy its OCC reporting obligations. According to the commenter, this
would avoid redundant reporting while preserving the OCC's supervisory
visibility into a permitted payment stablecoin issuer's financial
condition. Another commenter stated that the OCC should instead work
through the Federal Financial Institutions Examination Council, or
FFIEC, to create a standalone payment stablecoin schedule within the
Call Report for institutions that already file Call Reports. The
commenter added that the Call Report schedules should remain the single
source of institution-level information on income, financial condition,
off-balance sheet items, and capital. For Federal nonbank permitted
payment stablecoin issuers and foreign payment stablecoin issuers, the
commenter added that the OCC could require a streamlined quarterly Form
PS-02 containing the stablecoin-specific items in the payment
stablecoin Call Report schedule.
Other commenters advocated for Form PS-02 submissions to satisfy
permitted payment stablecoin issuers quarterly reporting obligations.
Several commenters stated that OCC-supervised banks should be exempted
from the obligation to submit Call Reports if their business primarily
involves issuing payment stablecoins and conducting activities
incidental to that issuance and redemption and if they comply with the
proposed quarterly reporting obligations via Form PS-02. One commenter
explained that the two forms of reporting would be largely duplicative.
The commenter further stated that to the extent the OCC or other
commenters identify relevant information gaps between Form PS-02 and
Call Report fields, the OCC could add additional schedules to Form PS-
02 or expand the scope of Schedule E. The commenter added that since
the OCC proposes to make information provided via Form PS-02 publicly
available, the public would not be disadvantaged if banks reporting via
Form PS-02 are exempted from requirements to submit Call Reports.
Several commenters stated that OCC-regulated permitted payment
stablecoin issuers and foreign payment stablecoin issuers should not be
required to file both the proposed stablecoin reporting forms and
duplicative Call Report items covering the same stablecoin data. One
commenter stated that best solution is a single, uniform, standardized
stablecoin dataset, distinct from the Call Report that provides
permitted payment stablecoin issuer-specific detail.
Another commenter stated that the OCC should extract the data
points it needs from the existing machine-readable Call Report and only
require entities to report data that is not already required to be
reported in the Call Report. The commenter claimed that this approach
will not only reduce reporting burden, but it will also likely improve
the integrity of the data reported because data is required to be
prepared once and duplication introduces the chance for errors.
Several commenters recommended that permitted payment stablecoin
issuers be required to file both Form PS-02 and the Call Report. One
commenter explained that requiring separate reporting would help
distinguish reporting related to GENIUS Act-authorized payment
stablecoin issuer activities from non-payment stablecoin issuer
activities, promoting transparency and allowing market
[[Page 66932]]
participants, regulators, and other stakeholders to consistently
compare information across issuers, regardless of charter type or
organizational structure. The commenter added that clear linking
instructions would further reduce reporting burden and ensure
consistency across reporting requirements. Another commenter stated
that the OCC should require additional reporting, such as the Call
Report, for all issuers that are authorized to engage in digital assets
service provider or other trust charter activities. The commenter also
stated that the OCC should not limit disclosure by these entities to
the information in the streamlined quarterly report and these
institutions should be required to submit a full Call Report. Another
commenter stated that the quarterly reporting framework should remain
permitted payment stablecoin issuer-specific and should not rely on
Call Reports or parent-entity reporting as a substitute for stablecoin
data. The commenter stated that Call Reports do not capture the
reserve, redemption, liquidity, token-supply, custody, technology,
affiliate, and operational-backstop information necessary for GENIUS
Act supervision. The commenter added that capital and operational-
backstop fields should be calibrated to permitted payment stablecoin
issuer continuity and orderly wind-down needs, including non-
discretionary operating expenses or tailored unwind costs, rather than
hard-wiring a 12-month total-expense measure into the reporting form.
The OCC believes that requiring a permitted payment stablecoin
issuer to provide a quarterly report of condition will allow the agency
and the public to understand a permitted payment stablecoin issuer's
financial condition, operations, and the risks unique to its business
model. This regular data reporting will also allow the OCC to tailor
its examinations to be risk-based, which will reduce the burden of
examinations. Further, the OCC acknowledges that there will be some
overlap between Form PS-02 and the Call Report. However, these two
reports are important and should remain because they serve two
different purposes. Call Reports convey information to the public about
the financial condition of a bank and Form PS-02 will convey
information to the public about the financial condition of a permitted
payment stablecoin issuer. Following implementation of the final rule,
the OCC will assess the quarterly reporting framework and consider if
permitted payment stablecoin issuer should be relieved of some
reporting obligations.
Several commenters provided feedback concerning the public
disclosure of Form PS-02 as well as the process for designating
confidentiality. One commenter expressed support for publishing
quarterly financial-condition information at an aggregate, decision-
useful level so the public can understand an issuer's financial
condition. Another commenter stated that the OCC should establish a
strong presumption that Form PS-02 information will be publicly
disclosed. The commenter explained that Form PS-02 will collect
information that is key to evaluating whether a permitted payment
stablecoin issuer can maintain sufficient reserves, meet redemption
obligations, manage operational and affiliate risks, and remain
financially sound. Another commenter stated that the OCC should narrow
the proposed confidential-treatment process. The commenter observed
that the instructions allow a reporting entity to seek confidential
treatment for ``some or all'' portions of Form PS-02 upon a showing
that disclosure would likely cause substantial competitive harm. The
commenter claimed that an issuer-by-issuer process could produce
inconsistent disclosure outcomes, reduce comparability across permitted
payment stablecoin issuers, and create unnecessary administrative
burden for both reporting entities and the OCC. The commenter further
added that confidential treatment should be limited to narrow,
predefined categories where disclosure would present specific
cybersecurity, operational, liquidity, counterparty, or market-
stability risks. Another commenter stated that the OCC should preserve
a clear distinction between confidential supervisory reporting and
public disclosures. The commenter stated that weekly reporting should
remain confidential and supervisory-only, particularly for
counterparty-specific, named-institution, custodian, wallet-level,
exchange, and secondary-market information. The commenter added that
public disclosure should instead be limited to aggregate, decision-
useful quarterly information that helps payment stablecoin holders and
market participants understand an issuer's financial condition without
revealing information that could enable front-running, destabilize
banking or custody relationships, or transmit stress between permitted
payment stablecoin issuers and their reserve counterparties.
The OCC's presumption is that each quarterly Form PS-02 for each
permitted payment stablecoin issuer will be publicly available. It is
vitally important that the public has access to timely and reliable
data concerning the financial condition of a permitted payment
stablecoin issuer. The availability of Form PS-02 is further consistent
with the GENIUS Act's requirement that permitted payment stablecoin
issuers publish their reserve composition monthly.\28\ However, the OCC
is maintaining the ability to grant a request for confidentiality when
the facts and circumstances warrant such accommodation. The OCC expects
to use this authority sparingly.
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\28\ See 12 CFR 15.13(e).
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One commenter recommended that the OCC prescribe RC-T-like
treatment for regulatory reporting. The commenter further recommended
that reserve assets and the corresponding redemption obligations should
be reported together in a proposed Schedule RC-PS, by stablecoin and
reserve category, with the reserve ratio and any deficiency clearly
disclosed. The commenter added that they should not be consolidated
into the permitted payment stablecoin issuer's ordinary assets and
liabilities reported on Schedule RC. The commenter further explained
that the issuer's corporate assets, liabilities, income, and capital
would remain in the existing Call Report schedules.
The OCC disagrees with this approach. The Form PS-02 will require
reporting entities to follow GAAP to ensure consistency in reporting.
As stated in the preamble to the final rule, the OCC generally
anticipates that reserve assets will be recorded on the permitted
payment stablecoin issuer's balance sheet under GAAP as the permitted
payment stablecoin issuer maintains ownership and control over the
reserve assets.
One commenter stated that for multi-issuance stablecoin brands,
public quarterly reporting should support brand-level transparency,
including consolidated circulating supply, aggregate reserve position,
and allocation of redemption responsibility across regulated
affiliates, while permitted payment stablecoin-specific supervisory
data should remain available to the OCC. The commenter added that
outstanding issuance value and reserve fields should be calibrated to
the payment stablecoins the permitted payment stablecoin issuer is
obligated to redeem, and the forms should distinguish treasury
stablecoins, frozen/blocked tokens, and tokens permanently removed from
circulation in a technology-neutral manner.
The OCC disagrees with the recommendation to have brand-level
[[Page 66933]]
stablecoin reporting transparency in the quarterly reports. Permitted
payment stablecoin issuers are required to provide brand-level public
reporting through their public monthly attestations. In addition,
permitted payment stablecoin issuers will be subject to brand-level
reporting through Form PS-01. The OCC believes that incorporating
additional brand-level stablecoin information into Form PS-02 would add
unnecessary burden, without a corresponding supervisory benefit or
benefit to the public.
One commenter recommended that the OCC align permitted payment
stablecoin issuers' reporting requirements with the Call Report's
reporting requirements and instructions wherever possible. The
commenter stated, for example, proposed Form PS-02's instructions
should define ``premises and fixed assets'' to also include right-of-
use assets in accordance with ASC Topic 842, Leases, consistent with
existing Call Report instructions.
As with the OCC's coordination with other primary Federal payment
stablecoin regulators, the OCC will make similar efforts to utilize,
where appropriate, common terminology drawn from Call Reports.
Several commenters provided feedback on Form PS-02's attestation
requirements. One commenter stated that the OCC should provide
flexibility for permitted payment stablecoin issuers to have their
Chief Executive Officer, or another executive, provide the necessary
declaration, rather than requiring the Chief Financial Officer to serve
as the declarant for every institution. The commenter stated that a
single accountable executive is the appropriate owner of the Form PS-02
reporting process, and the executive responsible for financial
reporting is best positioned to oversee the preparation of the
reporting, review the relevant controls and reconciliations, and make a
meaningful declaration as to its accuracy. The commenter added that
some institutions may prefer to vest this responsibility with the chief
executive officer or another executive, and the OCC should provide
flexibility for filers to make that election. The commenter also
suggested that the OCC narrow the attestation requirement such that
only three directors are necessary to attest to the accuracy of Form
PS-02. Another commenter stated that the OCC should not require each
director and member of senior management of a foreign payment
stablecoin issuer to sign and attest to the accuracy of Form PS-02. The
commenter stated that this requirement would present a significant and
unnecessary burden on foreign payment stablecoin issuers, particularly
where directors and senior management are located internationally.
The attestation requirements flow from the final rule.\29\ As
stated in the final rule, the OCC believes that the Chief Financial
Officer, or the individual performing the equivalent function, is the
correct member of senior management to be accountable for providing an
attestation to the accuracy of quarterly reports. A single accountable
member of senior management will help ensure that a member of senior
management has ownership of a permitted payment stablecoin issuer's
financial reporting function. Similarly, the OCC believes that
requiring all members of the board of directors and senior management
to attest to the correctness of quarterly reports will help ensure that
the board of directors and senior management are engaged in the
oversight of the permitted payment stablecoin issuers' financial
reporting function. Upon implementation, the OCC will continue to
assess the rule's requirements along with those of the reporting forms
and the associated reporting burden.
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\29\ See 12 CFR 5.14(i)(2) and (3); and 15.31(b)(2).
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Another commenter stated that the OCC should require additional
reporting regarding third-party payments and other arrangements that
may function as indirect yield, growth incentives, or economic
substitutes for interest. The commenter added that Form PS-02 should
capture the economic substance of such arrangements, including the
parties involved, the activities that trigger payment, whether
compensation is tied to balances or transaction volume, and whether the
arrangement is designed to increase stablecoin holdings or usage. The
commenter also stated that Form PS-02 should also provide sufficient
detail regarding material derivatives, digital asset contracts,
affiliate exposures, special-purpose vehicles, and off-balance-sheet
arrangements to assess whether such exposures could affect redemption
capacity, reserve management, capital, operational resources, or risk
transmission to community banks and the broader financial system.
The OCC disagrees with this recommendation. The information the
commenter proposes to collect is unnecessarily granular, may be
challenging to implement in practice, and would yield information of
minimal supervisory value. To the extent necessary, the OCC could
nevertheless obtain this type of information, through the supervisory
process.
Schedule A--Income Statement
Proposed Schedule A would collect an income statement including
information about reserve asset income and expense, other income and
expense, and net income. Proposed Schedule A separates (1) income and
expenses associated with a permitted payment stablecoin issuer's or a
foreign payment stablecoin issuer's stock of reserve assets from (2)
income and expenses associated with other corporate activities. Items 1
and 2 of proposed Schedule A would collect information on income and
expenses associated with reserve assets, while Items 4 and 5 of
proposed Schedule A would collect information on other income and
expenses.
In the notice, the OCC invited comment on modifications to these
items or any additions. One commenter stated that the OCC should work
with other primary Federal payment stablecoin regulators to standardize
the definitions of reserve income, reserve expense, other income, and
other expenses across the Federal GENIUS Act framework. The commenter
added that a shared data dictionary among the primary Federal payment
stablecoin regulators would help ensure that comparable payment
stablecoin issuers report the same concepts in the same way and would
reduce the risk of divergent reporting practices across federal
pathways.
As discussed throughout this notice, the OCC has, and continues to,
coordinate closely with the other primary Federal payment stablecoin
regulators. The OCC will continue to work with the other primary
Federal payment stablecoin regulators to harmonize terminology, where
appropriate, across the agencies' respective reporting forms.
Revised Schedule A
The OCC is not proposing to change Schedule A of Form PS-02.
Description of Revised Schedule A
Revised Schedule A would collect an income statement including
information about reserve asset income and expense, other income and
expense, and net income. Revised Schedule A separates (1) income and
expenses associated with a permitted payment stablecoin issuer's or a
foreign payment stablecoin issuer's stock of reserve assets from (2)
income and expenses associated with other permitted payment stablecoin
issuer corporate activities. Items 1 and 2 of revised Schedule A would
collect information on income and expenses associated with reserve
assets, while
[[Page 66934]]
Items 4 and 5 of revised Schedule A would collect information on other
income and expenses.
Schedule B--Balance Sheet
Proposed Schedule B would collect a balance sheet including
information about reserve assets, other assets, liabilities, and
capital. Proposed Schedule B would require reporting each asset's value
in accordance with U.S. GAAP.
In the notice, the OCC invited comment on proposed Schedule B. One
commenter stated that the balance sheet should align with the reserve
values reported in Schedule C of proposed Form PS-01 and Schedule E of
proposed Form PS-02 to avoid inconsistent reserve measures across the
reporting forms. The commenter recommended that the OCC make clear that
reserve sufficiency is measured by fair value even where a particular
accounting treatment may permit amortized-cost presentation for
financial-statement purposes. The commenter also recommended that the
Federal payment stablecoin regulators publish a standardized set of
terminology so reserve assets, other assets, liabilities, capital, and
related valuation fields map consistently across weekly reporting,
quarterly reporting, and any Call Report appendix or integrated filing
process. According to the commenter, that approach would improve
comparability, reduce reconciliation risk, and support harmonized
reporting across Federal payment stablecoin regulatory regimes.
The terminology and requirements of Forms PS-02 are drawn from the
final rule and the GENIUS Act. Upon implementation, the OCC will
consider adding additional definitions or clarification as warranted.
Revised Schedule B
The OCC is proposing minor revisions to Schedule B of Form PS-02.
The OCC is incorporating several revisions to the asset and liabilities
reporting categories into a revised Schedule B. First, the OCC is
changing the heading of Item 3 from ``Operational backstop'' to
``Operational backstop assets.'' Second, under the assets category, the
OCC is adding a new sub-category at Item 8, Goodwill and Intangible
Assets. The OCC is also adding Item 8.a, which requires a permitted
payment stablecoin issuer to report goodwill on its balance sheet
separate from other intangible assets, which will be reported in new
Item 8.b. The instructions for Item 8.b, formerly Item 8 under proposed
Schedule B, also no longer list ``goodwill'' as an intangible asset
that needs to be reported under Item 8.b.
Under the liabilities category of revised Schedule B, the OCC is
modifying Items 13 and 14 to include the following sentence at the end
of the instructions for each column, ``If applicable, include any
Operational backstop debt reported on Schedule D: Capital and
Operational Backstop, item 9.'' The OCC is adding this language to the
instructions for these items for consistency with the addition of
section 15.40(c), Operational Backstop Debt, which was not in the
proposed rule.
The OCC is incorporating the remainder of proposed Schedule B into
revised Schedule B without any revisions.
Description of Revised Schedule B
Revised Schedule B would collect a balance sheet including
information about reserve assets, other assets, liabilities, and
capital. Revised Schedule B would require reporting each asset's value
in accordance with U.S. GAAP.
Schedule C--Off-Balance Sheet Items
Schedule C would collect information about off-balance sheet items
including off-balance sheet assets (excluding derivatives), off-balance
sheet liabilities (excluding derivatives), and derivatives (including
forward contracts, futures contracts, and exchange-traded and over-the-
counter options contracts).
Revised Schedule C
The OCC is proposing technical changes to Schedule C of Form PS-02
to clarify the information collected. Proposed Item 1 (Off-balance
sheet assets (excluding derivatives)) required reporting of total off-
balance sheet assets required to be disclosed under U.S. GAAP and a
subset of off-balance sheet assets that exceed certain thresholds. To
improve clarity, the proposed line item will be split into two new line
items, revised Item 1 ``Total off-balance sheet assets (excluding
derivatives)'' and revised Item 2 ``Off-balance-sheet asset detail
(excluding derivatives)'' with substantively identical reporting
instructions to the proposed form. Similarly, proposed Item 2 (Off-
balance-sheet liabilities (excluding derivatives)) will also be split
into revised Item 3 ``Total off-balance-sheet liabilities (excluding
derivatives)'' and revised item 4 ``Off-balance-sheet liability detail
(excluding derivatives).'' Due to the additional line items, proposed
Items 3 and 4 have been renumbered to revised Items 5 and 6, with no
changes to the proposed reporting instructions.
Description of Revised Schedule C
Revised Schedule C would collect information about off-balance
sheet items including off-balance sheet assets (excluding derivatives),
off-balance sheet 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
Proposed Schedule D would collect additional information about a
permitted payment stablecoin issuer's capital elements. Proposed
Schedule D would also collect information about a permitted payment
stablecoin issuer's operational backstop, including information about
the total expense for the previous 12 months and the composition of
assets of the operational backstop.
As a part of the notice, the OCC invited comment about proposed
Schedule D. One commenter stated that Schedule D directs the reporting
entity to report its total expenses for the preceding twelve months,
computed from specified income-statement items, and that figure sizes
the operational backstop the issuer must hold in liquid assets.
However, according to the commenter, the instructions do not address
how charges paid to an affiliate are treated. The commenter stated that
a services charge priced to a target return is reported gross as an
operating expense, but part of it is a distribution of profit rather
than a cost of operating: it is payable only after the issuer satisfies
its regulatory capital and liquidity requirements and, depending on the
governing agreement, abates or is waived on a wind-down. The commenter
noted that the OCC asked whether the calculation of total expenses
warrants adjustments of this kind and explained that amounts that
cannot become a cash outflow in the conditions the backstop exists to
fund are a candidate, and they are distinct from the reclassification
of ongoing operating expenses as one-time items that the OCC identified
as a concern.
Revised Schedule D
The OCC is proposing several substantive revisions to Schedule D of
Form PS-02 to conform to changes in Subpart E, Capital and Operational
Backstop, of the final rule. The following changes are being
incorporated into a revised Schedule D.
First, the OCC is removing Items 1 through 6 from proposed Schedule
D and replacing them with seven new
[[Page 66935]]
items. Generally, these revisions are being made to conform the
reporting form to changes to the capital calculation in the final
rule.\30\
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\30\ See the final rule titled Implementing the Guiding and
Establishing National Innovation for US Stablecoins Act for the
Issuance of Stablecoins by Entities Subject to the Jurisdiction of
the Office of the Comptroller of the Currency published elsewhere in
this issue of the Federal Register.
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Item 1 of revised Schedule D requires permitted payment stablecoin
issuers to report the total equity capital reported in revised Schedule
B, Item 23.
Item 2 requires a permitted payment stablecoin issuer to report the
goodwill figure from revised Schedule B, Item 8.a.
Item 3 requires a permitted payment stablecoin issuer to report the
intangible assets less goodwill figure from revised Schedule B, Item
8.b. and digital assets that meet the U.S. GAAP definition of an
intangible asset that are reported in revised Schedule B, Item 6.
Item 4 requires a permitted payment stablecoin issuer to report the
amount of deferred tax assets that arise from net operating loss and
tax credit carryforwards, net of associated valuation allowances.
Item 5 requires a permitted payment stablecoin issuer to report
operational backstop assets funded by equity from revised Schedule D,
Item 10.
Item 6 is the sum of Items 2 through 5 of revised Schedule D.
Item 7 requires permitted payment stablecoin issuers to report
capital elements which is the total of Item 1 (Total equity capital)
less Item 6 (Total capital deductions).
Under the Operational Backstop section of revised Schedule D, the
OCC is moving Item 7 (12-months total expenses) from proposed Schedule
D to Item 11 in revised Schedule D. The new Item 11 contains two
clarifying revisions. First, ``months'' and the citation ``12 CFR
15.41(b)'' in the first sentence have been revised to ``months' '' and
``12 CFR 15.41(a)(2),'' respectively. The OCC is also changing the
heading of Item 11 from ``12-month total expenses'' to ``Operational
backstop requirement'' for clarity. The OCC has also updated the
instructions to Schedule D to state that one-time expenses that are
wholly unrelated to the continuing operation of the permitted payment
stablecoin issuer may be excluded from the calculation of the previous
12 months' total expenses in Schedule D, Item 11 if the permitted
payment stablecoin issuer has received prior written approval from the
OCC pursuant to 12 CFR 15.41(b)(1)(iii).
The OCC is also changing the heading of Item 8 from ``Composition
of operational backstop'' to ``Operational backstop assets'' for
clarity. Also, under Item 8, the OCC is also adding Item 8.e, which is
simply a total of Items 8.a through 8.d.
The OCC is also adding a new category of information, Operational
backstop debt, as Item 9. Item 9 requires permitted payment stablecoin
issuers to report the total amount of operational backstop debt that
meets the requirements outlined in 12 CFR 15.40(c). The instructions
further explain that the reported debt cannot exceed 50 percent of the
amount reported in revised Schedule D, Item 11 (Operational backstop
requirement).
The OCC is also adding a new Item 10, which requires permitted
payment stablecoin issuers to report the operational backstop assets
funded by equity. This figure is the total of Schedule D, Item 8.e
(Total operational backstop assets) less Schedule D, Item 9
(Operational backstop debt).
Finally, the OCC is adding a new Item 12, which requires permitted
payment stablecoin issuers to report the minimum capital amount that
the permitted payment stablecoin issuer must hold based on the
requirements in 12 CFR 15.41(a), as of the report date.
Description of Revised Schedule D
Revised Schedule D would collect additional information about a
permitted payment stablecoin issuer's capital elements. Revised
Schedule D would also collect information about a permitted payment
stablecoin issuer's operational backstop, including information about
the total expense for the previous 12 months and the composition of
assets of the operational backstop.
Schedule E--Memorandum
Proposed Schedule E would collect additional information about a
permitted payment stablecoin issuer's or a foreign payment stablecoin
issuer's operations, including issuer type, other reserve asset income
and expenses, other income and expenses, other assets and liabilities,
number of branded stablecoins issued, non-U.S. dollar assets and
liabilities, average reserve assets, stablecoin issuances, redemption,
and burn data, blockchains, redemption metrics, and custody activities.
As a part of the notice, the OCC invited comment on proposed
Schedule E. Several commenters recommended that the OCC require the
token-level DTI instead of, or in addition to, the blockchain name in
Item 14.a of proposed Schedule E, so that per-ledger issuance and
redemption figures tie to a specific, externally verifiable token
implementation rather than a non-standardized market label.
As previously discussed, the OCC has revised the reporting forms,
including revised Schedule E, to collect DTI information where
appropriate.
Revised Schedule E
The OCC is proposing a version of Schedule E of Form PS-02 with
several substantive revisions. The following changes are being
incorporated into a revised Schedule E. First, the OCC is incorporating
Items 1 through 8 as proposed in proposed Schedule E. Second, for Item
9, the OCC is including, generally as proposed, the text that
corresponds to Option B in proposed Schedule E. As discussed in the
final rule, the OCC eliminated the safe harbor option, so the OCC is
including the text associated with Option B, which does not relate to
the proposed safe harbor. The text of Item 9 in revised Schedule E
includes one minor conforming change. The term ``Asset Diversification
and Concentration'' is changed to ``Reserve asset diversification and
concentration.''
Revised Schedule E also incorporates substantial modifications to
Item 13 and Items 13.a through 13.g. Specifically, the OCC has removed
Items 13.a through 13.g from proposed Schedule E and replaced those
items with the issuance and redemption categories from Form PS-01,
revised Schedule A, Item 1 (Daily outstanding payment stablecoins). The
only difference being that the reported categories in revised Schedule
E relate to issuance and redemption across the entire reporting period
instead of a single day. Otherwise, the composition of the information
collection is identical. Item 13 has also been modified to reflect that
the categories of information being collected now spans Items 13.a
through 13.k instead of Items 13.a through 13.g. Item 14 seeks the same
information as Items 13.a through 13.k, with the primary difference
being that the OCC is requiring permitted payment stablecoin issuers to
provide this information broken down by each blockchain upon which a
stablecoin is issued. Finally, Items 15, 15.a, 15.b, and 15.e include
technical modifications to reflect that the OCC consolidated proposed
Schedules A and B into revised Schedule A in Form PS-01.
The OCC is not proposing any changes to the remainder of proposed
Schedule E and incorporating it into revised Schedule E.
[[Page 66936]]
Description of Revised Schedule E
Revised Schedule E would collect additional information about a
permitted payment stablecoin issuer's or a foreign payment stablecoin
issuer's operations, including issuer type, other reserve asset income
and expenses, other income and expenses, other assets and liabilities,
number of branded stablecoins issued, non-U.S. dollar assets and
liabilities, average reserve assets, stablecoin issuances, redemption,
and burn data, blockchains, redemption metrics, and custody activities.
Estimated Burden
The OCC estimates the burden of this collection of information as
follows:
Estimated Frequency of Response: Weekly and quarterly.
Summary of Estimated Total Annual Burden:
----------------------------------------------------------------------------------------------------------------
Estimated Estimated Estimated Estimated
number of frequency of average hours annual burden
respondents response per response hours
----------------------------------------------------------------------------------------------------------------
Initial Set-up
----------------------------------------------------------------------------------------------------------------
Reporting Burden:
Section 15.14(h).......................... 39 1 16 624
Section 15.14(i).......................... 39 1 80 3120
Section 15.31(b)(2)(i).................... 1 1 80 80
Section 15.31(b)(2)(ii)................... 1 1 1 1
-----------------------------------------------------------------
Total Initial Set-up Reporting Burden. .............. .............. ............... 3,825
----------------------------------------------------------------------------------------------------------------
Ongoing Compliance
----------------------------------------------------------------------------------------------------------------
Reporting Burden:
Section 15.14(h).......................... 39 52 2 4,056
Section 15.14(i).......................... 39 4 16 2,496
Section 15.31(b)(2)(i).................... 1 1 80 80
Section 15.31(b)(2)(ii)................... 1 1 1 1
-----------------------------------------------------------------
Total Ongoing Compliance Reporting .............. .............. ............... 6,633
Burden...............................
-----------------------------------------------------------------
Estimated Total Annual Reporting .............. .............. ............... 10,458
Burden...........................
----------------------------------------------------------------------------------------------------------------
Total estimated annual burden hours: 10,458 (3,825 hours for initial setup and 6,633 hours for ongoing
compliance). On June 11, 2026, the OCC published the proposed forms and instructions with an estimated total
annual reporting burden of 6,308 hours.\31\ The above reporting burden estimates represent revised estimates
of the total annual reporting burden. The estimated total annual reporting burden has increased primarily for
two reasons.\32\ First, the OCC increased the total number of permitted payment stablecoin issuer respondents
from 30 to 40. This figure has been revised upwards to reflect the OCC's increased expectations for the number
of permitted payment stablecoin issuers. Second, the estimated total annual burden has also increased because
the OCC has increased the estimated weekly reporting burden from 1 hour to 2 hours. As discussed below, the
OCC has increased this estimate to better capture the scope of the information sought through the weekly
reporting form. As a result of these two revisions to the underlying assumptions, the total estimated annual
reporting burden has increased by 4,150 hours.
The weekly and quarterly reporting information collections and their accompanying burden estimates were
published in the Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for
the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the
Currency final rule published elsewhere in this issue of the Federal Register. This notice is re-publishing
those same estimates here for informational purposes.
Discussion of the Comments Received in Response to the Standard PRA
Prompts
---------------------------------------------------------------------------
\31\ See OCC Bulletin 2026-24, ``GENIUS Act: Reporting Forms and
Instructions for Permitted Payment Stablecoin Issuers Subject to the
Jurisdiction of the Office of the Comptroller of the Currency,''
(June 11, 2026), <a href="https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-24.html">https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-24.html</a>; see also 91 FR 35795.
\32\ The estimate has also increased by an additional two hours
to reflect the inclusion of the line item for section
15.31(b)(2)(ii).
---------------------------------------------------------------------------
(a) Whether the collection of information is necessary for the
proper performance of the functions of the OCC, including whether the
information has practical utility.
In response to the request for feedback on whether the collection
is necessary for the proper performance of the functions of the OCC,
including whether the information has practical utility, the OCC
received several comments expressing support for some or all of the
proposed collection and several comments questioning the necessity and
justification of the proposed information collection. One commenter
expressed support for the proposed collection on the grounds that the
data is important to the assessment of the financial health of
permitted payment stablecoin issuers. The commenter also added that the
collection of information is also important to payment stablecoin
holders to appropriately evaluate the issuance. Another commenter
expressed support for the weekly reporting on the grounds that the
proposed weekly reporting seeks the right information at the right
cadence. Another commenter stated that the collection is necessary but
commented on the completeness and enforceability of the proposed
reporting.
In contrast, another commenter stated that the cadence of the
weekly reporting has no analogue in the ordinary prudential reporting
the OCC requires of a national bank in sound condition. The commenter
further added that the notice does not explain why the Call Report and
the GENIUS Act's monthly, independently examined reserve report leave a
supervisory gap requiring weekly reporting.
As discussed in the final rule, the OCC is adopting a weekly and
quarterly reporting cadence.\33\ The OCC has determined that a weekly
and quarterly reporting cadence will provide the agency with sufficient
data and supervisory visibility into permitted payment stablecoin
issuers.\34\
---------------------------------------------------------------------------
\33\ See the final rule titled Implementing the Guiding and
Establishing National Innovation for US Stablecoins Act for the
Issuance of Stablecoins by Entities Subject to the Jurisdiction of
the Office of the Comptroller of the Currency published elsewhere in
this issue of the Federal Register.
\34\ See id.
---------------------------------------------------------------------------
Another commenter noted that a list of the 100 largest addresses is
not a list of the 100 largest holders, and the
[[Page 66937]]
collection contains no attribution information that would permit the
OCC to convert the one into the other. The commenter further claimed
that with respect to this particular item, the collection is justified
on a stated rationale that the instrument does not deliver.
As discussed above, the OCC has revised the information collection
related to the largest holders to only capture those holders that hold
2 percent or more of the outstanding issuance balance. The OCC is
collecting this information to understand a permitted payment
stablecoin issuer's concentration risk.
(b) The accuracy of the OCC's estimate of the burden of the
collection of information.
The OCC received several comments concerning the burden estimates
in the notice. Several commenters claimed that the burden estimates
predate the reporting forms and were not derived from the forms and
instructions. The commenters also questioned the estimate of one hour
weekly to prepare the Form PS-01 due to volume and granularity of the
data to be collected and recommended that the OCC estimate burden based
on the proposed forms.
In contrast, several other commenters expressed the view that the
proposed reporting is either a byproduct of data permitted payment
stablecoin issuers already produce internally or that after the initial
setup of the reporting function, the ongoing reporting burden is
minimal.
In response to these comments, the OCC has elected to review its
burden estimates associated with the ongoing compliance reporting
burden. Upon review, the OCC has determined that an upward revision to
the estimate of weekly ongoing compliance reporting burden for Form PS-
01 from one hour to two hours is appropriate. The increase in the
estimate of the weekly ongoing compliance reporting burden reflects the
OCC's acknowledgement that the agency is seeking a substantial amount
of information and that this information takes time to compile,
validate, and submit. The OCC considered allocating additional time to
the preparation and submission of Form PS-01 but ultimately concluded
that the revision to two hours was appropriate because the OCC's
expectation is that a permitted payment stablecoin issuer will collect
many, if not all, of the data points sought by Form PS-01 in real time.
For example, permitted payment stablecoin issuers are required to
constantly maintain reserve assets backing their payment stablecoins at
a ratio of at least 1:1. In order to ensure continuous compliance with
this requirement, a permitted payment stablecoin issuer should have
internal controls to monitor in real-time the total outstanding
issuance of its payment stablecoins and its total reserve assets. The
maintenance of these fundamental controls should allow a permitted
payment stablecoin issuer to readily produce reporting about the
issuance and redemption of its payment stablecoins and its reserve
asset composition. This data can be incorporated directly into Form PS-
01 or at least inform the figures that ultimate populate Form PS-01.
Similarly, the OCC expects that a permitted payment stablecoin issuer
would have internal control to monitor on-chain activity and this on-
chain surveillance could be utilized to populate certain transaction
and market data required by Form PS-01. In sum, Form PS-01 seeks a
substantial amount of data, but the OCC expects permitted payment
stablecoin issuers to have internal control systems capable of
generating much of the information sought through the form.
In the final rule, the OCC estimates a total annual compliance
burden associated with the submission of Form PS-01 of 4,056 hours.
This represents an increase of 2,548 hours from the estimate in the
June 12, 2026, notice.\35\
---------------------------------------------------------------------------
\35\ The increase in total annual hours reflects both the
increase in weekly compliance hours from one to two as well as an
increase in the number of respondents from 29 to 39.
---------------------------------------------------------------------------
(c) Ways to enhance the quality, utility, and clarity of the
information to be collected.
In response to the request for feedback on ways to enhance the
quality, utility, and clarity of the information to be collected, the
OCC received several comments containing recommendations covering a
variety of topics including reporting format and structure and data
fields. One commenter recommended that the OCC collect a weekly
minimum, maximum and average reserve asset coverage ratio--i.e.,
reserve assets against outstanding issuance--similar to FDIC PS-01a.
The commenter claimed that this information would enhance the utility
of the information collected at negligible additional burden Another
commenter cited the feasibility challenges of collecting, reconciling,
and producing data at a weekly interval.
The OCC declines to collect this information because the OCC can
calculate this information from the data reported across Forms PS-01
and PS-02.
Another commenter recommended that the OCC adopt a monthly
reporting cadence instead of weekly reporting to improve both
feasibility and information quality.
As discussed in the final rule, the OCC is adopting a weekly and
quarterly reporting cadence.\36\ The OCC has determined that a weekly
and quarterly reporting cadence will provide the agency with sufficient
data and supervisory visibility into the stablecoin market.
---------------------------------------------------------------------------
\36\ Id.
---------------------------------------------------------------------------
Another commenter recommended that the OCC allow sufficient time to
reconcile and evidence reserve balances and tokens in circulation,
rather than require publication of unsupported figures.
As discussed above, the OCC has modified the reporting period to
provide permitted payment stablecoin issuers with an additional 24
hours each week to generate and file Form PS-01. The OCC believes this
additional time is sufficient to allow permitted payment stablecoin
issuers to perform adequate quality control processes to ensure that
reported data is accurate.
Two commenters recommended that the OCC require the use of LEIs for
the identification of OCC-supervised permitted payment stablecoin
issuers and foreign payment stablecoin issuers in the general
instructions for Forms PS-01 and PS-02. The commenter stated that
requiring the use of LEIs for regulatory reporting is essential to
eliminate data ambiguity, ensure high quality, and improve systemic
risk monitoring.
Under the instructions for Forms PS-01 and PS-02, if a permitted
payment stablecoin issuer has an LEI, the permitted payment stablecoin
issuer must include that information along with each report. However,
of note, the instructions do not require a permitted payment stablecoin
issuer to obtain an LEI for purposes of filing either Form PS-01 or
Form PS-02.
Another commenter recommended that the forms and instructions
permit, without requiring, reported figures to carry independently
verifiable evidence.
The OCC declines to allow reported figures to carry independently
verifiable evidence. The OCC does not allow national banks and Federal
savings associations to report data with independently verifiable
evidence, so the agency is not going to extend such functionality to
permitted payment stablecoin issuers. If the OCC observes a need for or
finds value in providing such functionality in the future, the agency
will consider incorporating such functionality into the forms.
[[Page 66938]]
One commenter stated that a common data dictionary is the single
most effective way to enhance the quality, utility, and clarity of the
information collected while reducing manual reporting burden and
recommended that the OCC coordinate with the other primary Federal
payment stablecoin regulators. Another commenter recommended that the
OCC require stablecoin issuance data to be prepared and collected
adhering to a standardized semantic data model. The commenter stated
that this will enhance the quality, utility, and clarity of information
collected because data will be prepared in alignment with a taxonomy
which provides concretely defined labels, data types, definitions and
other properties.
As discussed above and in the final rule, on June 25, 2026,
pursuant to the FDTA \37\ the OCC and other Federal agencies issued a
joint final rule establishing joint data standards.\38\ In addition to
the joint rule, the FDTA also directs each agency to issue individual
rules adopting applicable joint standards for certain collections of
information under their respective purview. The OCC has not issued its
agency-specific rulemaking adopting applicable joint standards. In
developing and finalizing the weekly, monthly, and quarterly reporting
forms, the OCC will ensure that the reporting forms are consistent with
the FDTA and the agencies' joint rule.
---------------------------------------------------------------------------
\37\ See The Financial Data Transparency Act of 2022, Public Law
117-263, title LVIII, 136 Stat. 3421.
\38\ See Financial Data Transparency Act Joint Data Standards,
91 FR 38246 (June 25, 2026).
---------------------------------------------------------------------------
(d) Ways to minimize the burden of the collection on respondents,
including through the use of automated collection techniques or other
forms of information technology.
In response to the request for feedback on ways to minimize the
burden of the collection on respondents, the agency received several
recommendations on ways to minimize burden. One commenter presented
several recommendations including specifying a structured, machine-
readable filing format for both forms, using the XBRL standard,
adopting a common ontology across all agencies and reporting regimes
containing defined terms and definitions related to blockchain and
digital assets, and harmonizing the OCC's and the FDIC's reporting
structures. Another commenter stated that the single most consequential
burden minimization measure would be the specification of a structured,
machine-readable format. Another commenter recommended utilizing
standardized machine-readable fields rather than recurring narrative
responses,
As discussed above, the OCC will ensure that the reporting forms
are consistent with the FDTA and the agencies' joint rule.
Similarly, another commenter recommended that the Federal
stablecoin regulators jointly adopt reporting forms. The commenter
stated that this would improve consistency, reduce burden, and align
with the statutory mandate of the GENIUS Act.
The OCC has coordinated closely with the other primary Federal
payment stablecoin regulators. Further, the OCC has taken seriously its
obligation to coordinate with other agencies, as appropriate, and does
not believe that it is necessary to do so through a joint rule or joint
reporting forms. The OCC will continue to coordinate with other Federal
payment stablecoin regulators as appropriate.
Another commenter stated that the OCC should revise Form PS-01 so
that Schedules A, D, E, G, and H only require weekly data, rather than
requiring end-of-day data for each calendar day in the reporting week.
Alternatively, the commenter stated that the OCC could require daily
data capture and reporting only upon notice from the OCC. The commenter
stated that a weekly snapshot would reduce the reporting burden on
permitted payment stablecoin issuers without eliminating supervisory
information and would also reduce the time required for the OCC to
review Form PS-01 submissions.
As discussed above, the OCC is amending the instructions for Form
PS-01 to reduce the weekly reporting burden on smaller issuers to allow
those issuers that are not currently subject to a formal enforcement
proceeding or order; have an outstanding issuance value, together with
any affiliated permitted payment stablecoin issuers, of less than $1
billion; and are in compliance with all of the reserve requirements set
forth in section 15.11 and the reporting requirements in section 15.14,
to satisfy their obligations for revised Schedules D through G by only
submitting the required data for the last day of the reporting period
(i.e., each Monday) for each payment stablecoin it issues. The OCC
believes this approach serves the goals of reducing the reporting
burden for smaller issuers while also ensuring that the OCC receives
the information necessary to supervise permitted payment stablecoin
issuers. In addition, once reporting has commenced, the OCC will
continue to assess the information collection and consider if further
revisions are warranted.
Another commenter explained that the daily reporting requirement
multiplies extraction, validation, reconciliation, exception
management, and data-governance work across each affected schedule.
According to the commenter, for Schedules B (Issuance and Redemption),
C (Reserve Assets), and F (Reverse Repurchase Agreements), this burden
is well justified by the supervisory value of monitoring data that
closely correlates with risks to permitted payment stablecoin issuers
or individual stablecoins. However, the commenter claimed that several
of Form PS-01's schedules are unlikely to have meaningful daily
fluctuations. Specifically, proposed Schedule A (General) primarily
tracks information on the largest wallets and most active exchanges.
The commenter explained that proposed Schedule A's data fields will
undoubtedly change daily because of ordinary settlement flows,
operational transfers, or short-lived trading activity, but these
changes are unlikely to provide insight into sustained concentrations
or material trends as compared to weekly snapshots and aggregates.
Similarly, the values in proposed Schedule D (Cash Balances) are likely
to exhibit daily noise as a result of normal operations without
corresponding supervisory value.
The commenter further explained that other Form PS-01 schedules are
more appropriate for weekly reporting precisely because they contain
numerous fields that will not change significantly from day to day.
Specifically, proposed Schedule E (U.S. Treasury Securities), proposed
Schedule G (Money Market Mutual Funds), and proposed Schedule H (Other
Instruments) are substantially composed of static and slow-changing
information. CUSIPs, coupon rates, maturity dates, custodians, and
other security-identification fields do not ordinarily change each day,
and so will be of little value for daily tracking in Schedule E. The
commenter added that the same is true for many of the money market
mutual fund fields in proposed Schedule G and the fields in proposed
Schedule H. Weekly reporting of fair value and amortized cost of
Treasuries, WAM, and ownership concentrations of money market mutual
funds, or fair value and WAM of other instruments in proposed Schedule
H should provide sufficient information for the OCC to permit effective
supervision.
The revisions to Form PS-01 reflect that the OCC considered these
comments. For example, the OCC
[[Page 66939]]
eliminated certain items from proposed Schedule A and refined the
information collected related to wallets to focus on data that is
relevant to the supervision of permitted payment stablecoin issuers. In
addition, once reporting has commenced, the OCC will assess the
information collection and consider further revisions are warranted.
For example, the OCC may consider modifying some data fields in Form
PS-01 from daily reporting to weekly reporting if they are found to be
static.
(e) Estimates of capital or start-up costs and costs of operation,
maintenance, and purchase of services to provide information.
Regarding the estimated capital and start-up costs, one commenter
stated that the proposed collection would, at a minimum, require the
procurement of analytics services and licensed market data.
The OCC has incorporated this information into its revised burden
estimates, which are discussed above.
Comments continue to be invited on:
(a) Whether the collection of information is necessary for the
proper performance of the functions of the OCC, including whether the
information has practical utility;
(b) The accuracy of the OCC's estimate of the burden of the
collection of information;
(c) Ways to enhance the quality, utility, and clarity of the
information to be collected;
(d) Ways to minimize the burden of the collection on respondents,
including through the use of automated collection techniques or other
forms of information technology; and
(e) Estimates of capital or start-up costs and costs of operation,
maintenance, and purchase of services to provide information.
Sarah E. Turney,
Assistant Director, Office of the Comptroller of the Currency.
[FR Doc. 2026-21705 Filed 10-22-26; 8:45 am]
BILLING CODE 4810-33-P
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</html>Indexed from Federal Register on October 23, 2026.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.