Who pays the stablecoin rewards matters as much as the rate. In its final GENIUS Act rule, issued October 21, the OCC dropped a proposed presumption that would have treated certain affiliate and third-party reward arrangements as violations unless rebutted. The ban on issuers paying yield solely for holding, using or retaining a payment stablecoin stays. So does the OCC’s authority to act against evasion. Arrangements now get reviewed case by case, and older programs get no safe harbor. Comparing dollar products? Follow the payment: who funds it, who pays it, what earns it. Effective Janua

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