Stablecoins: who gets the yield?

Stablecoins are digital tokens designed to track the value of a currency, often the US dollar. The assets backing USDC, Circle’s dollar stablecoin, earn interest. Circle shares part of that income with partners, including the cryptoasset platform Coinbase. Holders may receive rewards from their platform under terms that depend on the contract and local rules. Redemption rights and reserve income therefore follow distinct paths. M07 P02 P01

On 21 October 2026, the Office of the Comptroller of the Currency (OCC), the US supervisor of national banks, announced its final rule implementing the GENIUS Act, the US law governing payment stablecoins. Published in the Federal Register on 23 October, it will take effect on 18 January 2027. Among other things, it governs payment stablecoin issuers within the OCC’s remit. The decisive change for customer rewards lies in a provision that was removed: the presumption proposed for certain indirect payments disappears from the final text. The prohibition on issuers and the powers to address evasion remain. L02 L01 L04

The decision opens a contest over contracts, distribution and legal classification. A platform may describe a reward as a loyalty programme; the regulator will examine who actually bears the payment and what it pays for. A bank may lose a customer’s deposits while the economy sometimes retains the same total, held elsewhere. A reserve may cover the tokens in circulation while its income flows through a chain of businesses, with the token holder receiving a share only under particular arrangements.

Power lies in the ability to distribute the digital dollar, capture its income and set the terms for getting out. Following these three functions makes the controversy much easier to understand than a comparison of two advertised rates alone.

Research cutoff: 29 October 2026, before Coinbase’s scheduled third-quarter release after the US market close. The financial statements examined cover the second quarter of 2026. Coinbase has scheduled its third-quarter results for after the US market close on 29 October; Circle has scheduled its release for 4 November. Future rules, published results and hypothetical examples are identified separately. All amounts are in US dollars unless stated otherwise. F04 F05

Holders’ rights over the assets backing USDC

Start with an entirely hypothetical example. A customer gives an issuer $1,000 and receives 1,000 tokens, each carrying a claim to redemption for one dollar under the product’s terms. The issuer holds a $1,000 reserve in eligible assets. If that reserve earns a simple annual return of 4%, with the principal held constant, it generates $40 over the year. The $1,000 is a stock of assets supporting redemption; the $40 is a flow of income. Adding them together as though they were a single promise to the customer is the first source of confusion.

Under Circle’s USDC terms for holders outside the European Economic Area, updated on 15 October 2026, holders acquire no right to the return earned on reserve assets. The right to redemption and the right to income are therefore contractually separate. This explains how a fully backed token can support a profitable business even when its holder receives no remuneration. Those terms have an explicit geographical scope; European contracts require examination within their own framework. P02

The forthcoming OCC rule requires coverage at least equal to the value of stablecoins in circulation, maintained at all times, with segregated reserves and provision for an additional buffer. It also regulates the withdrawal of any excess. In our example, the $40 of gross income therefore remains an economic measure: its actual availability still depends on reserve requirements, expenses and other applicable constraints. An asset return and a distributable dividend arise at different stages. L01

This separation also appears in USDC’s actual structure. The examination report dated 26 October 2026 covers two snapshots of the reserves in September. At 23:59 UTC on 30 September, it records approximately $73.879 billion of USDC in circulation under its definitions, against $73.957 billion of reserve assets at fair value. It examines a coverage assertion at those dates, with specified adjustments and exclusions. Such a snapshot describes the assets backing the tokens defined in the report. Assessing liquidity during a crisis also requires following maturities, banks and the arrangements for accessing funds. P03

Part of the reserve is held through a money market fund whose shares belong to Circle. The USDC holder retains a claim associated with the stablecoin; the fund shares and their income sit elsewhere in the structure. The same economic exposure to government securities can therefore underpin products carrying very different rights. Understanding what a customer owns requires identifying the claim, the party that owes it and the conditions for converting it into bank money. P03 P02

Circle pays for its dollar to be used

Circle’s accounts show the price of reaching customers. In the second quarter of 2026, its reserve income reaches approximately $668 million within roughly $701 million of total revenue. Distribution and transaction costs account for about $410 million, with $2 million of other costs. That leaves roughly $289 million before operating expenses, under Circle’s company-defined measure Revenue Less Distribution Costs, or RLDC. The figure retains the precise published amounts. F01

These figures describe a business fuelled by reserves and paying heavily for access to customers. The issuer can create a redeemable monetary unit; its usefulness depends on where people can accept it, exchange it, hold it and use it. A platform controlling those points of contact has bargaining power over the income generated upstream. Stablecoin economics thus combines asset management with the distribution of a means of payment.

The Coinbase agreement makes that power visible. Circle describes payments linked to USDC held on the platform, after an issuer retention, together with half of the residual ecosystem income after certain payments to approved third-party participants. The public formula therefore has several layers. The passage examined leaves Circle’s retention rate undisclosed. Reducing this agreement to a uniform 50/50 split of all interest would erase much of its structure. F01

The economic significance is more revealing than the slogan: investing the same reserve dollar can generate different income for the platform depending on where the token is held and the agreements governing its use. Two USDC balances that appear identical to their owners can therefore have different commercial value for the businesses distributing them. The contest concerns customer journeys, uses and the length of time a balance stays within a particular environment.

Circle’s investor communications present RLDC alongside other performance measures. Assessing the business requires reading on to operating expenses and the resulting earnings. Reserve income, income after distribution and profit measure successive stages. A comparison that jumps directly from reserve size to profit would attribute to the company amounts already owed to partners or needed to run its operations. F03

Coinbase is also buying a customer relationship

Coinbase records the same ecosystem through different reporting lines. In that quarter, it reports approximately $292 million of stablecoin revenue and $119 million of USDC rewards expenses, classified under sales and marketing. Subtracting the second line from the first leaves about $173 million before other items. Calculating profit would require the costs and accounting effects of the rest of the business. F02

The customer programme can therefore be understood as spending on acquisition and retention. A platform chooses to return some of the economic value to users to attract their balances, encourage them to stay and develop a commercial relationship. The offered rate depends on that strategy as well as the reserve return. Users can benefit; the platform expects the broader relationship to justify the expense.

Coinbase’s FAQ describes its rewards as a loyalty programme funded by Coinbase. It explains that terms vary by country, eligibility and programme, and that the rate can change. Some markets require a Coinbase One subscription. These conditions call for comparing the benefit actually received after fees and eligibility requirements over a defined period. This dossier fixes no current promotional rate: a generic page provides too little information to establish the offer available to every account. P01

The two companies’ accounts require another precaution. Circle records $324.6 million of costs under its Coinbase agreement for the quarter. This amount forms part of its distribution costs and exceeds Coinbase’s published stablecoin revenue line. Since the first quarter of 2026, Coinbase has classified income from its own stablecoin holdings under “corporate interest and other income”. The company states that it has reclassified the comparatives and that the presentation leaves total revenue and the Circle agreement unchanged. F01 F02

These amounts offer two accounting views of the same partnership. Circle’s costs and Coinbase’s revenue use different definitions. Payments between companies, reported revenue and customer rewards each have their own scope. The public documents establish the main lines while leaving their complete reconciliation unresolved. F01 F02

Interest rates put pressure on the split

The business model depends on both the volume of stablecoins and the return on their reserves. Circle’s results show these forces moving in opposite directions. Between the second quarters of 2025 and 2026, average daily USDC circulation rises from $61.039 billion to $76.524 billion. The reported reserve return, rounded to one decimal place, falls from 4.1% to 3.5%. Reserve income nevertheless increases from $634.274 million to $667.733 million. F01

A larger base can therefore offset a lower return. That observed result leaves open how much growth will be available in the next quarter. Its main value is to separate the two drivers. An issuer can substantially expand the use of its token while earning less income per reserve dollar. The pressure on distribution terms will then depend on how quickly each of those forces moves.

Circle also publishes a financial sensitivity over twelve months. In a scenario involving a 100-basis-point decline, equivalent to one percentage point, the shock is applied uniformly from 1 July 2026 and maintained for twelve months, with circulation held at its 30 June level and reserve composition kept constant. Reserve income would fall by $737 million and distribution and transaction costs by $360 million. The calculated difference is a decline of $377 million before other effects. This is a static sensitivity exercise with stated assumptions, separate from the observed quarterly results. F01

Data and calculations

Circle’s published sensitivity: a −100 basis point shock on 1 July 2026, a twelve-month horizon, constant circulation and allocations. USD millions; the final row is an arithmetic difference.

Scenario change relative to its baseline

Measure	Change · $m
Reserve income	-737
Distribution and transaction costs	-360
Derived difference before other items	-377

The analytical value of the exercise lies in how the shock is shared. Partners receiving a fraction of reserve income also absorb some of the decline when rates fall. The issuer retains the residual exposure. If a platform simultaneously promises customers a reward, its own budget depends on the gap between incoming revenue, the duration of its commercial commitment and the speed at which it can change the terms.

A rate cut can therefore prompt several responses: a lower reward, additional revenue elsewhere, a search for higher volumes or acceptance of a larger commercial expense for a time. These are economic possibilities whose implementation depends on each company’s contracts and decisions. Public accounts reveal the exposure while offering much less visibility into future commercial choices.

The stability of the token’s price thus conceals variability in the income surrounding it. A balance can remain displayed at one dollar per unit while the interests of the issuer, platform and customer shift. This changing allocation is precisely what the rules on remuneration seek to govern.

The OCC turns attention to the contracts

The GENIUS Act, enacted on 18 July 2025, prohibits a covered issuer from paying a holder interest or yield, in various forms, solely in connection with holding, use or retention of the stablecoin. The word “use” matters: a reward linked to activity also requires examination of its actual purpose. The statute gives the regulator powers to address evasion as well. L03

The final rule defines the holder as the beneficial owner. When a platform holds tokens for a customer, its technical control and the customer’s beneficial ownership therefore occupy distinct positions. This definition allows the recipient of remuneration to be followed beyond the address holding the tokens. L01

The OCC proposal published on 2 March 2026 sought to address certain indirect arrangements through a rebuttable presumption: a combination of relationships and payments could lead the regulator to presume a prohibited payment, subject to contrary evidence. The final rule abandons that approach. The OCC explains, among other reasons, that it could capture lawful arrangements and create a misleading impression about those falling outside its criteria. L04 L01

Removing the presumption changes the method of supervision. In its preamble, the OCC retains its analysis of an agent paying on an issuer’s behalf and of a transfer intended simply to have a third party make a payment prohibited to the issuer. It distinguishes services actually provided while reserving examination of the facts. Classification therefore depends on the agreement, the function of the payment and the relationship between the parties. L01

The useful question becomes: what service does each payment buy? A distribution payment may purchase access to a commercial network, infrastructure or a service. Money passing through an intermediary can also serve to remunerate holders on the issuer’s behalf. Across these situations, the words in a commercial presentation reveal the product’s positioning; contractual obligations help establish the substance.

This approach gives weight to details often missing from announcements: who sets the rate, what triggers payment, whether the recipient can freely allocate the income received, what service is supplied in return and who bears the risk when reserve interest falls. Together, these questions provide an investigative framework. The public contracts examined shed light on parts of it; legally classifying an individual programme would require the full record and the facts of its operation.

The OCC’s choice could consequently affect competition. Companies able to document their services, commercial independence and payment flows have an advantage in discussions with the supervisor. An apparently simple offer may prove costly to substantiate when it combines several companies, multiple counterparties and rights that are difficult to trace. This is our interpretation of the framework’s implications; the regulator has made no such competitive finding.

The timetable must remain visible. On 29 October, the final rule has been published and its effective date lies ahead. Its scope covers the activities and entities specified by the OCC; anti-money-laundering provisions, sanctions and certain other obligations follow their own texts. The 18 January 2027 milestone operates within that scope, alongside the other rules governing offers around the world. L02 L03

A bank deposit can change hands

The other contest concerns banks. A customer moving money into a stablecoin can take a deposit relationship away from their bank. The aggregate balance sheet, however, depends on what happens next. Federal Reserve researchers distinguish the volume, composition and concentration of deposits. A footnote to a speech by the chairman of the Federal Deposit Insurance Corporation (FDIC), the US federal deposit insurer, also describes how buying a government security from a nonbank participant can place the deposit in the seller’s hands. M01 M02

Take another hypothetical $1,000 example, following only that amount. Initially, the customer holds it on deposit at bank A. When the stablecoin is issued, the money reaches the issuer’s account at bank B. The issuer then buys an existing Treasury bill from a nonbank investor, who receives payment into an account at bank C. At each of the three stages, the circuit being traced contains $1,000 of deposits. At the end, the customer holds the tokens, the issuer holds the government security and the seller holds the bank deposit.

This mechanism relies on specific conditions: primary issuance of the stablecoin, a secondary-market purchase and a nonbank seller receiving a deposit. Other transactions produce other effects. Buying a security owned by a bank, paying funds into the Treasury’s account or passing through certain money-market investments changes the accounting entries to follow. Customers’ bank deposits and the reserves banks hold at the central bank are also distinct objects. M01 M02

The example reconciles two experiences. Bank A has indeed lost a deposit and may need to replace it. In the circuit described, the total being followed remains within the system. Credit effects can vary with the rates offered, the stability of the new depositors and bank C’s ability to deploy the funds. Moving from an individual outflow to a forecast of nationwide contraction therefore requires a further model.

The identity of the depositor matters as much as the amount. A dispersed customer base, deposits concentrated among a few companies and balances that can move rapidly have different funding characteristics. A bank can receive more deposits while facing a more mobile funding base or a higher cost. Conversely, a lost deposit can be replaced with another source of funding, affecting margins and lending terms. This transformation of bank funding is what the Federal Reserve note invites readers to examine. M01

The issue also has a geographical and commercial dimension. Even when two movements offset each other in an aggregate, the banks gaining and losing funds may serve different customers. Assessing the risk requires asking who loses the relationship, what it costs to replace it and who receives the new funds. Preserving a total in an accounting scenario leaves these distributional questions open.

Banks and platforms defend their revenue streams

The reactions to the final rule express this competition. On 21 October, the American Bankers Association highlights the risk that indirect rewards could weaken the prohibition and encourage deposit outflows. The Blockchain Association welcomes removal of the presumption. Both organisations represent sectors defending their economic interests. Their statements reveal what is at stake in the negotiations; the regulatory text establishes the obligations. M03 M04

The strongest banking argument concerns funding. More competition for balances can raise the rate needed to retain depositors or move funds towards institutions less involved with particular groups of customers. The strongest platform argument concerns passing some of the income generated by a balance to the customer and competing with existing products. Both mechanisms can operate simultaneously. Their importance depends on the scale of the movements and how banks respond.

A study by the Council of Economic Advisers, the White House’s economic advisory body, published in April 2026 provides a numerical answer within its model: prohibiting stablecoin yield would increase bank lending by approximately $2.1 billion, or 0.02%, with a net economic welfare cost of $800 million a year. These numbers are outputs from a US administration scenario. They do not measure an observed effect of the October rule, which followed the study. M05

The result depends, among other things, on a static framework, competitive banks, the absence of uncertainty and an ample-reserves regime. Under those assumptions, preventing remuneration produces a limited credit gain at the expense of a benefit to holders. The report therefore offers a structured argument against estimates that mechanically turn each stablecoin dollar into a dollar of lost credit. Its explanatory value must be assessed alongside its assumptions. M05

A fuller analysis would follow adjustments over time: changes in deposit rates, the cost of replacement funding, the distribution of inflows among banks and the volume of credit extended. It would also examine differences between institutions and market conditions. An aggregate model can illuminate the scale of an effect while leaving open the particular difficulties facing one bank or a group of borrowers.

The debate would therefore benefit from comparing explicit mechanisms. When a scenario predicts a contraction in lending, what share of the funds actually leaves bank deposits? What funding replaces it? Which interest rate responds? When another scenario finds a minimal effect, what capacity to adjust does it assume? These questions turn a contest of striking numbers into a discussion that can be checked.

From tokens to dollars available in a bank account

Income attracts the customer; the exit reveals the quality of the claim. The USDC terms for holders outside the European Economic Area distinguish eligible Circle Mint account holders from other holders. Direct redemption requires an eligible account in good standing and compliance with the stated conditions. For a user going through a platform, the experience therefore also depends on the chosen intermediary and its own route to the issuer. P02

The forthcoming OCC rule specifies a redemption deadline: no later than two business days, subject to its conditions for receiving the order and the applicable identification and legal requirements. It defines completion to include a fully processed and initiated transfer, or the requested credit to the customer’s account with the issuer. Final receipt in an external bank account is a further stage. L01

The diagram requires several moments to be distinguished: the token transfer, an instruction to an intermediary, the issuer’s receipt of an eligible order, initiation of payment and final availability. An interface can make the early stages fast while subsequent steps depend on identification procedures, banking systems and business days. For the customer, the useful measure is the time needed to recover usable funds at the chosen destination.

The rule also provides a stress mechanism. When requests exceed 10% of the circulating value of a stablecoin brand within twenty-four hours, the issuer must notify the OCC within the prescribed period and may request a discretionary extension. The final text drops the automatic seven-day extension contemplated in the proposal. The threshold therefore triggers supervisory treatment, while any extension remains subject to the applicable process. L01 L04

The March 2023 episode involving Silicon Valley Bank shows why this chain deserves as much attention as asset composition. A Federal Reserve analysis published in December 2025 traces difficulty accessing part of USDC’s reserves, pressure on its secondary-market price and the sequence involving announced protection for SVB depositors followed by resumed redemptions. The historical record documents transmission of banking risk into the stablecoin; it provides no probability of a recurrence. M08

A reserve can contain high-quality assets and still encounter difficulty accessing, selling or transferring them when needed. The product’s safety therefore depends on several links: asset value, liquidity, custody, banking channels and operational capacity. Adding intermediaries introduces further dependencies, a subject also examined in Federal Reserve research on stablecoins in 2025. M07

Legal status completes the picture. The GENIUS Act provides holders with a proportional priority claim on required reserves if the issuer becomes insolvent. The OCC framework requires disclosure that the stablecoin itself lacks federal deposit insurance and a US government guarantee. A priority claim establishes the order of rights; the amounts recovered and their timing still depend on the assets and the proceedings. L03 L01

Europe writes the distributor into the rule

Europe’s Markets in Crypto-Assets Regulation (MiCA) sets a different boundary. For e-money tokens, which track one official currency, Article 50 prohibits issuers and the relevant crypto-asset service providers from granting interest related to those tokens. It covers, among other things, remuneration or benefits linked to holding duration, including certain equivalent benefits provided by third parties. Article 40 takes a similar approach to asset-referenced tokens. The corresponding titles have applied since 30 June 2024. M06

The difference lies in how the scope is written. In the United States, the analysis examined here begins with the issuer prohibition and the treatment of indirect payments. In MiCA, the service provider appears directly in the applicable provision. This changes the starting point for an inquiry into a remuneration programme. Classifying a particular commercial promotion still requires examining the product, service, duration and consideration involved.

A transaction-linked benefit can operate differently from an amount paid in proportion to the time a balance is held. The labels “reward”, “cashback” and “loyalty” describe a commercial offer; its legal classification follows from its terms. This reading is particularly useful when the same group offers services in several countries. A translated interface can conceal different contracts, entities and rights.

The product a customer acquires also requires precise identification. A payment stablecoin, a bank deposit represented by a token and a money market fund share give the holder different claims. The GENIUS Act expressly excludes deposits, including tokenized deposits, from its payment stablecoin definition. Moving the interface into a digital wallet preserves the need to identify the legal instrument and its governing rules. L03

This boundary becomes strategically important when customers seek both access and income. Several products can offer exposure to short-term interest rates while carrying different redemption rights, liquidity and protections. A serious comparison therefore starts with the contractual promise, then examines expected income, fees and the ability to exit. A wallet’s shared interface leaves those distinctions between rights intact.

Every advertised rate has a budget behind it

The calculator below explores these economics in a deliberately simple and entirely hypothetical setting. It holds principal constant for one year, assumes a simple annual reserve return, allocates a fraction of that income to the platform and applies a customer reward rate. It calculates gross flows. Operating expenses, taxes, losses, prudential buffers and legal constraints sit outside the model; its parameters describe a hypothetical allocation, distinct from the actual terms of the Circle–Coinbase agreement.

With $1 million of principal, a 4% reserve return generates $40,000. Allocating 50% of the income gives the platform $20,000 and leaves the same amount for the issuer, before their other expenses and constraints. If the platform grants the customer 1.5% of principal over the year, it pays $15,000 and retains $5,000 within that income budget.

The arithmetic threshold at which allocated income covers rewards is 2%: 4% multiplied by 50%. At a 3% reward rate, payments reach $30,000 against $20,000 of allocated income. The additional funding requirement is $10,000. Other revenue or a commercial budget can fund that difference; calculating a net loss would require the complete accounts. The model shows where the funding requirement arises while leaving the company’s decision open.

The exercise also reveals two independent levers. A higher reserve return increases the income available. A larger fraction allocated to the platform changes the split between businesses. With the reward held constant, both changes can improve the platform’s budget, with different effects on the issuer. The customer sees a rate; the businesses also negotiate the division of the income that finances it.

The calculator runs locally, with bounded inputs and verified decimal arithmetic. It asks for no account, wallet connection or personal data. Results represent economic assumptions, while the eligibility of a payment and the availability of distributable income depend on the contracts and applicable rules. The method and inputs remain visible in the page alongside a calculated starting example.

l0g / STABLECOINS / LOCAL CALCULATOR

Divide the income from a fictional reserve

Fictional example over one year, with a constant reserve and simple annual rates. These inputs describe a teaching model rather than a Circle or Coinbase contract.

Principal kept in the reserve : $1,000,000.00

Change the four assumptions

Constant principal and simple annual rates

Principal (USD)Reserve return (% per year)Platform share of reserve income (%)Customer reward (% of principal per year)

Restore fictional example

Principal: $0 to $1 billion. Reserve and reward rates: 0% to 20%. Platform share: 0% to 100%. Up to two decimal places; decimal point or comma, without thousands separators.

Annual reserve income

$40,000.00

Issuer share before other costs

$20,000.00

Platform allocation before rewards

$20,000.00

Annual customer rewards

$15,000.00

Platform remainder before other items

$5,000.00

Additional funding required

$0.00

Reward rate covered by this allocation

2 %

Method and limits

Reserve income = principal × reserve return. The platform allocation is reserve income × its share; rewards = principal × reward rate. The remainder is the allocation less rewards. A negative remainder creates an additional funding need within this model.

For a positive principal, the arithmetic threshold equals reserve return × platform share. At zero principal, this rate is unavailable. It measures the reward budget before every other cost.

Principal stays separate from income. Operating costs, taxes, losses, reserve buffers, financing and legal restrictions fall outside the exercise. Actual distributable income and reward eligibility depend on the applicable rules and contracts.

Money is calculated exactly in integer units, then rounded independently to cents. Displayed amounts can therefore differ by a cent when added.

Calculations run in this page. Inputs remain in memory while it is open.

Competition will turn on income sharing and redemption

The OCC’s final rule makes documentation of the relationships between issuers, distributors and customers more important. Useful scrutiny will focus on the services actually being paid for, the independence of reward programmes and changes to terms as rates move. An intermediary’s presence calls for examination of the function it performs and the risk it bears.

The accounts will reveal another development: how much growth comes from volumes, how much from rates and how much remains after distribution. Holders, in turn, can compare the reward actually received, the fees required to access it and the time needed to convert into bank money. These measures connect the commercial promise to the service delivered.

For banks, the central issue will be the transformation of funding. Deposit movements will need to be followed institution by institution and then placed within their investment circuit. For public authorities, the trade-offs concern competition for balances, lending conditions and the robustness of claims used as means of payment. These objectives can pull rules in different directions; evaluating them requires data on flows and their recipients.

The digital dollar thus supports two kinds of distribution. It circulates a payment claim among users. Around that claim, it allocates reserve income and commercial power. Who ultimately receives that income will be determined by contracts, competition for the customer and the ability of the rules to follow a payment to its true recipient.

Further reading

• Stablecoins: from reserves to available dollars
• USDC reserves and rights under MiCA
• Stablecoins and capital gains in France

Sources and references

Documents checked on 29 October 2026. Published accounts, current or future rules and calculation scenarios retain their period and scope.

1. L01 · Office of the Comptroller of the Currency / Federal Register via Govinfo · Published : 2026-10-23 · Effective : 2027-01-18Final rule implementing the GENIUS Act for entities subject to OCC jurisdiction

   Central evidence for removal of the rebuttable presumption, retention of the issuer prohibition and fact-specific supervision. Covers reserves, redemption and indirect arrangements.

   Passages and scope

   DATES p.67000; yield preamble pp.67026–30; §15.2 beneficial owner; §15.10(c)(4),(6), p.67178; §15.11; §15.12(a),(c),(d), pp.67180–81; §15.31(c).

   Distinguish operative rule, OCC interpretation and commenters’ arguments. No individual program is approved. Effect is future at the research cutoff. The preamble leaves the then-proposed FDIC pass-through rule unresolved.

2. L02 · Office of the Comptroller of the Currency · Document : 2026-10-21 · Published : 2026-10-21 · Effective : 2027-01-18OCC Bulletin 2026-50: final stablecoin rule

   Establishes announcement and effective dates and the classes of entities covered by the OCC framework.

   Passages and scope

   Bulletin date; Summary; Note for Community Banks; Highlights.

   Official summary: L01 supplies the operative detail. Bulletin announcement date differs from Federal Register publication.

3. L03 · United States Congress / Congress.gov · Document : 2025-07-18GENIUS Act ; Public Law 119-27 of 18 July 2025

   Defines payment stablecoins, reserve coverage, the yield prohibition, supervisory powers, holder priority and statutory timing.

   Passages and scope

   §2(22) definition; §4(a)(1),(2),(11), 139 Stat.425–432; §4(h)(1) anti-evasion; §§6–7 supervision and enforcement; §11 insolvency; §20 effective date.

   Document date is enactment; first PDF upload date is unestablished. Issuer categories have different supervisory routes. Penalty amounts are maxima subject to statutory conditions.

4. L04 · Office of the Comptroller of the Currency / Federal Register · Published : 2026-03-02Proposed GENIUS Act implementing rule ; 91 FR 10202

   Verifies what was removed: a rebuttable presumption for certain affiliate/third-party arrangements and automatic redemption-period extension in stress.

   Passages and scope

   Interest/yield and rebuttable-presumption preamble pp.10211–10212; proposed §15.10(c)(4); proposed §15.12(c).

   Proposal language must not be presented as final operative provisions. Redemption paragraphs were renumbered.

5. F01 · Circle Internet Group, Inc. / SEC EDGAR · Document : 2026-08-05 · Published : 2026-08-05Form 10-Q ; quarter and half year ended June 30, 2026

   The accounts separate reserve income and distribution costs. The report describes Coinbase allocations, circulation, reserve returns and a rate-sensitivity exercise.

   Passages and scope

   MD&A: metrics and definitions pp. 44–45; income and Coinbase agreement pp. 46–47; Q2 results pp. 49–50 and H1 pp. 51–52; reserves pp. 57–58; Item 3 sensitivity p. 61.

   Unaudited interim accounts. Rounded management attribution of volume/rate effects. RLDC precedes operating expenses and includes other activities. Sensitivity holds circulation constant and is separate from observed results.

6. F02 · Coinbase Global, Inc. / SEC EDGAR · Document : 2026-07-30 · Published : 2026-07-30Form 10-Q ; quarter and half year ended June 30, 2026

   Stablecoin revenue now excludes income on Coinbase corporate stablecoin holdings. USDC rewards expenses appear in sales and marketing.

   Passages and scope

   Note 2 p. 10: reclassification; Note 5 p. 13: revenue; operating expense note p. 26; MD&A pp. 32–34: revenue and rewards.

   The 2025 comparatives come from the same filing and have been reclassified. Reported revenue and rewards do not constitute segment profit. The corporate line contains multiple income sources; exact reconciliation to Circle fees remains incomplete.

7. F03 · Circle Internet Group, Inc. · Document : 2026-08-05 · Published : 2026-08-05Circle Reports Second Quarter 2026 Results

   Cross-check for publication date and company metrics. Figures use the more precise Form 10-Q data.

   Passages and scope

   Financial tables and key metrics.

   Some amounts are rounded to whole millions; their sum can differ from the rounded total. Use F01 for calculations.

8. F04 · Coinbase Global, Inc. · Document : 2026-10-14 · Published : 2026-10-14Coinbase Announces Date of Third Quarter 2026 Financial Results

   The calendar date alone does not make the results available: Coinbase schedules publication after the US market close.

   Passages and scope

   Opening paragraph.

   Schedule announcement; no Q3 figures used at the evidence cutoff, which precedes the release scheduled after the US market close on 29 October.

9. F05 · Circle Internet Group, Inc.Circle Reports Third Quarter 2026 Results

   The page schedules the Q3 presentation for November 4.

   Passages and scope

   Event heading and description.

   First publication date is unknown; the event is in the future at access time.

10. M01 · Board of Governors of the Federal Reserve System ; FEDS Notes · Document : 2025-12-17 · Published : 2025-12-17Banks in the Age of Stablecoins: Some Possible Implications for Deposits, Credit, and Financial Intermediation

    Separates deposit quantity, composition and concentration. Effects depend on the origin of demand and the allocation of reserve assets.

    Passages and scope

    §2.1–2.4: demand origin, composition and concentration; §3: credit channels; final disclaimer.

    A signed staff analysis, not a Board decision. Channels are conditional. The 2025 reserve shares do not describe October 2026.

11. M02 · Federal Deposit Insurance Corporation · Document : 2026-03-11 · Published : 2026-03-11An Update on Reforms to the Regulatory Toolkit

    Footnote 34 follows funds from the stablecoin buyer to the reserve-asset seller and distinguishes deposit distribution from quantity.

    Passages and scope

    Stablecoins section; footnote 34; discussion of pass-through insurance and tokenized deposits.

    A speech alone does not establish a final rule. Pass-through discussion describes a proposal. Text read through the primary-site search index; direct open returned HTTP 403.

12. M03 · American Bankers Association ; ABA Banking Journal · Document : 2026-10-21 · Published : 2026-10-21OCC finalizes stablecoin rule with narrow payment-of-interest prohibition

    The ABA criticises the narrow rule and links deposit competition to banks’ funding of local communities.

    Passages and scope

    Article body and Rob Nichols statement.

    Primary evidence of banking-industry advocacy. The OCC text controls the legal reading; the statement does not prove a quantity of lost credit.

13. M04 · Blockchain Association · Document : 2026-10-21 · Published : 2026-10-21Blockchain Association Statement on Office of the Comptroller of the Currency’s Final Rule Implementing the GENIUS Act

    The association welcomes removal of the third-party-payment presumption and says its members had requested that change.

    Passages and scope

    Lindsay Fraser statement.

    An industry-interest statement. The rule’s reach and reward-programme conditions must be derived from the final text.

14. M05 · Council of Economic Advisers ; Executive Office of the President · Published : 2026-04-08Effects of Stablecoin Yield Prohibition on Bank Lending

    In the model’s baseline, a yield ban produces $2.1 billion of additional lending (+0.02%) and an $800 million annual net welfare cost. The report traces the flow of funds.

    Passages and scope

    Printed p. 1: results; pp. 2–3: Where Does the Money Go?; p. 4: static model, no uncertainty, ample reserves; p. 5: competitive banking; p. 14: Table 2 and annual welfare cost. Cover = PDF page 1.

    An administration simulation, distinct from an observed causal estimate. The baseline relies on strong assumptions; it does not quantify a run, reserve concentration or the actual effect of October’s rule.

15. M06 · Union européenne ; texte MiCA reproduit par l’ESMA · Document : 2023-05-31 · Published : 2023-06-09Regulation (EU) 2023/1114 ; Articles 40, 50 and 149

    Articles 40 and 50 cover issuers and CASPs for ARTs and EMTs. Benefits related to holding duration fall within the interest definition.

    Passages and scope

    Art. 50(1) issuer, (2) CASP, (3) definition; Art. 40 corresponding ART rules; Art. 149(2)–(3) application dates.

    European scope for the relevant categories. The link to holding duration matters; not every commercial gift is automatically captured. Product and service status requires separate analysis.

    MiCA, article 40 · MiCA, article 149

16. M07 · Board of Governors of the Federal Reserve System ; FEDS Notes · Document : 2026-04-08 · Published : 2026-04-08Stablecoins in 2025: Developments and Financial Stability Implications

    Analyses intermediation chains, vertical integration and growing connections with traditional financial infrastructure.

    Passages and scope

    Introduction; §III, three vulnerabilities; final disclaimer.

    The authors’ analysis, not an official Board position. April reserve shares and market capitalisations are not October 2026 figures.

17. M08 · Board of Governors of the Federal Reserve System ; FEDS Notes · Document : 2025-12-17 · Published : 2025-12-17In the Shadow of Bank Runs: Lessons from the Silicon Valley Bank Failure and Its Impact on Stablecoins

    Documents transmission from SVB to USDC, the weekend primary-market shutdown and continued secondary trading.

    Passages and scope

    Summary; §1.1 Primary Market Shutdown; Figure 1; §1.2 Secondary Market Activity.

    A historical episode, not an estimate of future crisis probability. SVB depositor protection and resumed redemptions belong to the same sequence; avoid attributing the entire recovery to a single cause.

18. P01 · CoinbaseUSDC Rewards Overview ; eligibility and reward mechanics

    Coinbase describes a platform-funded loyalty programme, daily accrual, weekly distribution and region-dependent eligibility. The page specifies insurance limitations and variable rates.

    Passages and scope

    Eligibility, About USDC Rewards, Rewards distribution, Rewards calculation and USDC Rewards rate sections.

    Coinbase’s own commercial documentation. It describes current terms rather than establishing a programme’s future compliance with the OCC rule. No universal or guaranteed rate is inferred.

19. P02 · Circle · Document : 2026-10-15USDC Terms ; version updated on 15 October 2026

    Terms outside the EEA separate par redemption from income earned on reserve assets. They distinguish Circle Mint customers from other holders and condition direct redemption on eligibility and account opening.

    Passages and scope

    Opening scope statement excluding EEA holders; §1 About USDC; §2 Scope of USDC and Key Terms; Claim on funds risk disclosure.

    Issuer contractual terms outside the EEA. They do not replace the statutory framework taking effect in January 2027 or Circle’s European documentation.

20. P03 · Independent accountants’ report and Circle Internet Group management · Document : 2026-10-26September 2026 USDC reserve examination report, dated 26 October

    The report examines the coverage assertion under its stated criteria at two specified dates. At 30 September it records 73,878,861,314 circulating USDC and $73,956,687,701 of reserve assets at fair value, under its defined scope.

    Passages and scope

    p.1: examination opinion and date; p.2: assertion, figures and criteria; pp.4–5: 30 September reserves; p.6: settlement adjustments and notes.

    Point-in-time coverage examination with defined token exclusions and settlement adjustments. It supplies neither a full group audit nor a continuous liquidity measure. September stocks are separate from quarterly income-statement flows.