The 87-Day Squeeze: Why the GENIUS Act Favors Incumbents

The arithmetic is the story: 87 days separate the October 23, 2026, delivery of the GENIUS Act’s stablecoin application forms to the Office of Management and Budget from the January 18, 2027, compliance date fixed by the GENIUS Act final rule . That gap is the entire runway between a rule that is final and a filing door that remains bolted shut. What fills it is not market speed, but the deliberate sequence of federal review. The stakes are not abstract. Under the OCC’s waiver guidance , issuing a payment stablecoin in the United States without prior approval after January 18, 2027, carries criminal penalties – and the statute offers no compliance implementation process for the issuers already operating here.

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