--- path: /blog/genius-act-rewards-white-label-stablecoins/ title: What the OCC’s final rule for the GENIUS Act means for rewards and white-label stablecoins on Tempo description: "The final OCC rule improves on their original proposal in areas that matter directly to Tempo and our partners: rewards, shared economics, and branded stablecoin issuance." image: /og/2026-q4/og_2026-q4_blog_genius-act-rewards-white-label-stablecoins_title-image_v01.jpg date: 2026-10-23 author: Tempo Team label: Deep Dive timeToRead: 3 socialTitle: "GENIUS Act: rewards and white-label stablecoins" locale: en canonical: https://tempo.xyz/blog/genius-act-rewards-white-label-stablecoins/ --- # What the OCC’s final rule for the GENIUS Act means for rewards and white-label stablecoins on Tempo The U.S. federal regulator, the Office of the Comptroller of the Currency (OCC), released its [final implementing rule](https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-50.html) for the GENIUS Act, with changes that are positive for the future of finance and Tempo and our partners. The GENIUS Act establishes a federal framework for payment stablecoin issuance in the United States. The Act and the OCC’s final rule take effect on January 18, 2027. While there are a number of important developments in the OCC’s final rule, there are two changes that are particularly relevant for businesses building on Tempo. ## Stablecoin rewards on Tempo The OCC originally proposed a "rebuttable presumption” that would have presumed a violation of GENIUS anytime an issuer paid an affiliate or “related third party” who in turn paid holders of the relevant stablecoin, unless the issuer could prove otherwise. The presumption was problematic because it created a high burden for issuers to overcome and may have had downstream impacts on how Tempo and its partners could utilize stablecoin rewards. In place of the rebuttable presumption, the OCC will use a substance-based test, which will look at the facts of an arrangement to determine if a particular arrangement violates GENIUS’ prohibition on yield solely for holding, using, or retaining a stablecoin. This allows for arrangements to be reviewed holistically and with context rather than from a position of a default rule violation. Overall, this leaves more flexibility for Tempo partners to receive stablecoin rewards and for Tempo partners to utilize rewards on end user experiences. Arrangements will continue to be subject to anti-evasion provisions and the OCC may issue further guidance on acceptable structures in the future, but at present, the OCC confirmed that there is flexibility to offer rewards so long as rewards are not being paid _solely_ for the holding, use, or retention of a stablecoin. This means, for example, that enterprises can continue to receive B2B fees for stablecoin marketing/distribution services, and rewards can be used to encourage the bona fide use of products or services (see Tempo [Earn](https://tempo.xyz/earn/) for more). Each arrangement requires its own unique analysis, which the Tempo team can help with. Tempo remains the best place to build with stablecoin rewards. ## White-label stablecoins on Tempo The OCC considered limiting each stablecoin issuer to a single brand but declined to adopt that restriction. It also declined to require a separate reserve pool for every stablecoin brand. This preserves the ability for Tempo partners to continue working with an issuer to launch stablecoins under their own brands as they are today. --- The final OCC rule improves on their original proposal in areas that matter directly to Tempo and our partners: rewards, shared economics, and branded stablecoin issuance. As you consider how stablecoins can work for your business, our team is here to help. --- ## Site links - [Tempo home](/) - [Privacy policy](/privacy-policy/) - [LinkedIn](https://www.linkedin.com/company/tempo) - [X](https://x.com/tempo) - [YouTube](https://www.youtube.com/@tempo) ### Products - [Earn](/earn/) - [Routes](/routes/) - [Zones](/zones/) ### Solutions - [Embedded finance](/solutions/embedded-finance/) - [Cross-border payments](/solutions/cross-border-payments/) - [Institutional settlement](/solutions/institutional-money-movement/) - [Agentic payments](/solutions/agentic-payments/) - [Tokenized deposits](/solutions/tokenized-deposits/) ### Developers - [Documentation](/developers) - [Tempo Explorer](https://explore.tempo.xyz/) - [Tempo API](/developers/docs/api/) - [Performance](/developers/performance) - [Status](https://status.tempo.xyz/) - [GitHub](https://github.com/tempoxyz) ### Resources - [Blog](/blog/) - [Customers](/customer-stories/) - [Ecosystem](/ecosystem/) - [Learn](/learn/) - [Reports](/reports/) - [OUSD](/ousd/) ### Company - [About](/about/) - [Careers](/careers/) - [Brand kit](/brand/) - [FAQ](/faq/)