OCC PS-01 and PS-02 Reporting: Weekly Reserves, Quarterly Condition

OCC PS-01 and PS-02 reporting now has final rule text behind it. On 21 October 2026 the Office of the Comptroller of the Currency issued its GENIUS Act final rule and, in OCC Bulletin 2026-52, revised versions of OCC Reporting Form PS-01 (Payment Stablecoin Activity and Reserve Weekly Reporting) and OCC Reporting Form PS-02 (Permitted Payment Stablecoin Issuer and Foreign Payment Stablecoin Issuer Reports of Condition and Income). Subject to approval by the Office of Management and Budget (OMB), the weekly collection takes effect as of the 25 January 2027 report date and the quarterly one as of the 31 March 2027 report date.

Both forms apply to every permitted payment stablecoin issuer (PPSI) supervised by the OCC and to every foreign payment stablecoin issuer (FPSI) registered with it. PS-01 is a confidential file, one per stablecoin, carrying daily data on issuance, redemption, wallet concentration, secondary-market prices and reserve assets down to individual Treasury CUSIPs. PS-02 is an entity-level income statement, balance sheet, capital and operational backstop report that the OCC presumes it will publish. Comments on the revised forms close on 23 November 2026.

The forms moved a long way from the June 2026 drafts: a new reporting week, one schedule fewer, a 2 percent holder threshold in place of a top-100 wallet list, tokenization flags on Schedules C to G and a lighter weekly path for issuers below $1 billion. Each change alters a data build that has to be running in January.

Related reading: FR UU Reporting: The Fed’s New Stablecoin Collection and FR Q Changes

PS-01 and PS-02 reporting dates for 2026 and 2027

• 18 July 2025: GENIUS Act enacted as Public Law 119-27 (12 U.S.C. 5901 et seq.).
• 12 June 2026: proposed PS-01 and PS-02 published for 60 days of comment (91 FR 35795; OCC Bulletin 2026-24). The period closed on 11 August 2026 with approximately 20 comments.
• 21 October 2026: final rule (OCC Bulletin 2026-50) and revised forms (OCC Bulletin 2026-52) issued.
• 23 October 2026: final rule published at 91 FR 67000; forms notice published at 91 FR 66916.
• 23 November 2026: 30-day Paperwork Reduction Act comment period on the revised forms closes.
• 18 January 2027: final rule effective.
• 25 January 2027: first PS-01 report date. The OCC states the first weekly report is due on 27 January 2027.
• 31 March 2027: first PS-02 report date, with the report due no later than 30 April 2027.

25 January 2027 is a Monday, so by my count the first weekly file covers Tuesday 19 January to Monday 25 January 2027. The collection’s start dates are subject to OMB approval; the rule takes effect on 18 January regardless.

Where the two forms sit in 12 CFR 15.14

The GENIUS Act sets the federal framework, and the OCC’s final rule implements it in a new 12 CFR part 15, “Payment Stablecoins”, while amending parts 3, 6, 8 and 19 of its regulations. Bulletin 2026-50 notes that Bank Secrecy Act, anti-money laundering and sanctions rules will follow separately with Treasury.

Section 15.14 carries the two recurring returns. Paragraph (h) requires every PPSI to submit “on a weekly basis, in the manner and form specified by the OCC, a confidential report”. Paragraph (i)(1) requires a quarterly report on financial condition, including the income statement, expenses, balance sheet, reserves, changes in equity, investments, capital, outstanding issuance value and assets under custody, in a standardized format and within 30 days of the end of the prior quarter. Paragraphs (i)(2) and (i)(3) add a chief financial officer declaration and a director and senior management attestation. Section 15.31(b)(2)(i) requires a registered FPSI to produce the same section 15.14 reports, plus any others the OCC requires.

The two forms sit alongside other part 15 reporting obligations. In particular, section 15.14(k) requires an AML and economic-sanctions programme certification not later than 180 days after approval of an application under section 15.30 and annually thereafter. The initial certification must be provided by the board of directors; subsequent certifications may be provided by the board, its appropriate committee or the Bank Secrecy Act officer. The following table summarises selected additional reports and does not constitute an exhaustive reporting calendar:

Compliance maps should cite the monthly composition report as section 15.11(e), where it sits in the published regulatory text, although one footnote in the forms notice points to section 15.13(e).

Who files, and why there is one PS-01 per stablecoin

Part 15 reaches a wider population than the two forms, which apply to PPSIs and registered FPSIs. Under section 15.2 a PPSI is a person formed in the United States that is either a subsidiary of an insured national bank or Federal savings association approved under section 15.30, a Federal qualified payment stablecoin issuer (a nonbank entity, an uninsured national bank chartered by the OCC, or a Federal branch), or a State qualified issuer subject to OCC authority under section 4 of the Act. The bank-chartered route therefore runs through an approved subsidiary of the insured bank or savings association. PS-02 Schedule E, item 1, asks each filer to declare which of those three types it is, or that it is an FPSI.

The filing unit differs between the forms. The PS-01 instructions require a separate PS-01, with all required schedules, for each payment stablecoin the PPSI or FPSI issues; PS-02 is filed once per reporting entity. PS-02 Schedule E, item 8, counts the branded stablecoins the entity issues and is legally responsible for redeeming, white-label coins included, and its own example gives three for an issuer with one own-brand coin and two white-label coins, each with reserves in clearly identified accounts. On my reading of the per-stablecoin rule, that issuer files three PS-01s every Wednesday.

Foreign issuers get no separate track. The OCC declined to tailor the forms for FPSIs or to accept home-country reports, since the final rule requires the same reports as for PPSIs, and rejected IFRS because requirements such as fair value and capital instruments are tied to US GAAP. Relief runs through a written request for exemption from a specific requirement under section 15.31(b)(2)(ii), granted at the OCC’s sole discretion; the notice adds that issuer- and jurisdiction-specific issues may also be addressed in licensing conditions or through Treasury comparability determinations and reciprocity agreements under section 18 of the Act (12 U.S.C. 5916). An EU e-money token issuer’s MiCAR returns, covered in our MiCAR reporting obligations guide, therefore remain a separate obligation from anything it would file with the OCC as a registered FPSI.

The same form codes appear at another agency. The FDIC proposed its own PS-01, a short-form PS-01a and a PS-02 for FDIC-supervised issuers in FIL-38-2026 on 17 July 2026, and the Federal Reserve Board proposed its GENIUS Act rules, including the FR UU collection, at 91 FR 61580 on 29 September 2026. The OCC rejected jointly adopted forms on the ground that each regulator must build reporting around its own mandate. Which “PS-01” an issuer files depends on its primary Federal payment stablecoin regulator.

The PS-01 week runs Tuesday to Monday on Eastern time

The PS-01 reporting period runs from 12:00:00 a.m. Eastern each Tuesday to 11:59:59 p.m. Eastern the following Monday. Every calendar day counts, weekends and holidays included; balances are taken as of 11:59:59 p.m. Eastern and activity covers the full Eastern day. Assets bought or sold during the week appear only for the days they were held. The file goes to the OCC through BankNet every Wednesday by 5:00 p.m. Eastern, and if that Wednesday is a Federal holiday it may be submitted on the first business day after.

The June proposal ran Wednesday to Tuesday against the same deadline, which one commenter calculated left approximately seventeen hours to collect, reconcile, approve and submit. The OCC kept Wednesday at 5:00 p.m. and moved the period back a day, an additional 24 hours in its words. By my count the gap is now about 41 hours.

Units shift inside a single schedule. Dollar amounts are reported in thousands, with items under $500 reported as zero, but the secondary-market prices go in as actual values to six decimal places, and the minimum, maximum and average redemption amounts and the wallet holdings go in as actual values. Dates use YYYY-MM-DD, gray shaded cells hold formulas and stay empty, and a field with no applicable value and no “not available” option is left blank. If a PPSI cannot file all or part of PS-01 on time, the instructions require a written notice of late filing, on or before the deadline, giving reasons in reasonable detail and the date by which the form will be filed.

Schedule A rolls outstanding issuance value forward each day

Schedule A, Issuance and Redemption, merges the June draft’s general and issuance schedules and is now the first of seven. Item 1 is a daily table for each blockchain, identified by its ISO 24165 Digital Ledger Identifier (DLI) where one exists. Columns B to F form a roll-forward: opening outstanding issuance value, plus stablecoins issued to customers, plus other changes, less stablecoins redeemed, gives the end-of-day figure in Column F, a formula cell. Column E captures par value added or removed for reasons unrelated to issuance or redemption, such as coins sent to a verifiable burn address.

Redemption timing follows section 15.12(a)(2): a redemption is deemed to occur when the issuer has fully processed and initiated the outgoing transfer, or credited the customer’s account with the issuer if the customer asked for that. On that definition, a request received on a Monday and paid out the next morning counts as a Tuesday redemption, which puts it in the following week’s file.

Columns G to I split redemptions by funding source. Column G takes redemptions paid directly from reserve assets with the coin burned at the same time; Column H takes redemptions funded from non-reserve assets where the coin stays outstanding in an issuer-controlled wallet; Column I catches the rest. Three end-of-day stocks follow: Column J for coins in issuer-controlled wallets not issued to customers, Column K for temporarily nonredeemable coins, such as those frozen through blacklist functions or time-locked by the issuer, and Column L for coins issued and not redeemed that are irretrievably lost or inaccessible.

Item 2 collects secondary-market pricing across the top 15 exchanges on which the coin trades: daily minimum and maximum executed prices, volume-weighted average price, peg deviation and the end-of-day bid/ask spread, excluding exchanges where a spread cannot reasonably be calculated. Item 3 holds liquidity measures, including coins paid for but not yet issued on-chain, coins tendered but not yet paid, average redemption time and the dollar amount of redemptions not initiated within two business days. Item 4 records the smallest, largest and average redemption.

Items 5 and 6 replace the June wallet lists. Item 5 reports the 20 wallet addresses with the largest cumulative redemptions each day, chosen because issuers have ready access to verifiable redemption data. Item 6 reports every address holding more than 2 percent of outstanding payment stablecoins at end of day, which the OCC says indirectly caps the list at 50. One commenter argued that the largest addresses are predominantly exchange omnibus accounts, bridge contracts and liquidity pools; Item 6 measures concentration by address, and the form has no field attributing an address to an owner. The June draft’s top 100 exchanges by trading volume and daily total exchange volume are gone.

Schedules B to G report reserve assets down to the CUSIP

Only reserve assets held under the GENIUS Act belong on the reserve schedules. The notice’s example is a Treasury security the issuer owns but does not hold as stablecoin backing, which stays off the Treasury schedule. Position data therefore needs a flag separating GENIUS Act reserves from corporate holdings before the first file.

Schedule B, Reserve Assets, reports daily across six categories: cash, money received under repurchase agreements, Treasury securities, money market funds, reverse repurchase agreements and other instruments. Each carries fair value, intraday minimum and maximum, amortized cost, tokenized balance, maturity measures, effective interest rate, interest retained and interest paid to third parties, and monetization from sales. Item 1.g totals reserve assets before repurchase agreement liabilities, item 1.h reports those liabilities, and item 2 nets them under the label “Total reserve assets net of outstanding repurchase agreement liabilities”, adopted after a commenter flagged a mismatch with the FDIC’s wording.

The October forms notice describes item 2 as gross reserve assets less outstanding repurchase-agreement liabilities. Section 15.2, however, defines reserve asset value by reference to the total fair value of reserve assets other than US coins and currency, net of any associated liabilities, plus the face value of US coins and currency. The reporting formula and the reserve-coverage calculation should therefore be reconciled where liabilities other than repurchase-agreement liabilities are associated with reserve assets. Item 3 lists the top five non-Federal Reserve Bank counterparties by aggregate exposure, and item 4 reports withdrawals made consistent with section 15.11(a)(4), excluding sales.

Schedule C reports cash reserves institution by institution: an RSSD ID for each US depository institution, insured and uninsured amounts and a tokenized-deposit flag, with Federal Reserve Bank balances as a separate item. The forms notice describes separate items for US and foreign depository institutions, while the instruction text dated 21 October 2026 shows a single cash-balances item. The visible Schedule C tab in the published PS-01 workbook (bulletin-2026-52c.xlsx) follows the instructions; the notice’s US and foreign split appears only on a hidden tab labelled OLD.

Schedule D stays at CUSIP level despite comments asking for maturity buckets, because the OCC considers Treasuries likely to be an issuer’s largest source of interest rate risk. Each security carries fair value, amortized cost, par, days to maturity and to the next rate reset, coupon, effective yield, custodian, sub-custodian, custody jurisdiction, any amount pledged under a repurchase agreement and a tokenization flag, followed by tables for repurchase agreements and their collateral. Schedule E covers reverse repurchase agreements, including collateral haircuts and whether rehypothecation is allowed. Schedule F, money market funds, swaps the June percentage-ownership field for a flag on holdings above 50 percent of the fund and the ticker for the fund’s LEI, if applicable. Schedule G is the catch-all, for example for physical cash, and the OCC said its existence is no invitation to hold impermissible reserve assets.

Schedules C to G now carry a Y/N tokenization indicator tied to the section 15.2 definition of tokenized form: an authoritative record kept on distributed ledger technology, with legal rights identical to the non-tokenized asset.

The Monday-only option for issuers below $1 billion

The OCC considered a truncated weekly form like the FDIC’s PS-01a and declined, holding that the weekly data is critical regardless of size. It cut frequency instead. The OCC’s forms notice describes the option in terms of permitted payment stablecoin issuers, while the 21 October 2026 PS-01 instructions extend it to a PPSI or FPSI. For an eligible issuer, Schedules D to G may contain only Monday data (the last day of the reporting period) when the following three conditions hold, the third being worded in the instructions by reference to the PPSI:

• it is not currently subject to a formal enforcement proceeding or order;
• its outstanding issuance value, together with any affiliated PPSIs, is less than $1 billion; and
• it complies with all reserve requirements in section 15.11 and the reporting requirements in section 15.14.

Schedules A to C still need every calendar day, and the OCC may, in its sole discretion, require an eligible filer to report all schedules daily. The notice says the criteria track the extended examination cycle in section 15.14(d), but that paragraph adds a fourth condition, no acquisition of control during the preceding 12-month period, which the PS-01 instructions omit.

PS-02 schedules: the public quarterly report of condition

PS-02 reports as of 11:59:59 p.m. Eastern on the last calendar day of each quarter and is due through BankNet no more than 30 calendar days later, rolling to the next business day when that falls on a weekend or Federal holiday. By my calculation the roll applies twice in the first year: the third-quarter 2027 deadline of 30 October is a Saturday and the fourth-quarter deadline of 30 January 2028 a Sunday, so both move to the following Monday. The OCC describes PS-02 as mirroring Call Report statements of condition, simplified for a less complex business model and prepared under US GAAP.

The carrying-value point in Schedule B is easy to miss. A footnote in the instructions states that compliance with section 15.11 is determined on fair value, while the balance sheet reports reserve assets at carrying value. On my reading, a portfolio with Treasuries carried at amortized cost can show one number on the PS-02 balance sheet and another on the PS-01 fair-value line, and both can be correct; Schedule E, item 16, which collects amortized cost and other supplemental reserve detail, is where the bridge shows.

Components of the “other” income and expense lines are itemised in Schedule E when they exceed $100,000 and 7 percent of the line, and components of other assets and other liabilities when they exceed $100,000 and 25 percent. Digital assets held to pay network or “gas” fees have their own balance sheet line. Schedule E, item 9, asks Yes or No on whether the issuer met every diversification and concentration requirement in section 15.11(c) on each business day, using the June draft’s Option B text because the proposed safe harbor was dropped. Items 13 and 14 reproduce the PS-01 roll-forward for the whole quarter, in total and by blockchain.

Asked how weekly stablecoin-level data reconciles to quarterly entity-level data, the OCC said the instructions’ cut-off times suffice for now and it will monitor problems after launch. One further inconsistency awaits the technical specifications: the PS-02 technical details call for dates in YYYY/MM/DD, while the PS-02 cover and all of PS-01 use YYYY-MM-DD.

Schedule D: capital after deductions and the operational backstop

Items 1 to 7 calculate capital after specified deductions. The revised PS-02 notice describes item 4 as deferred tax assets arising from net operating loss and tax-credit carryforwards, net of associated valuation allowances. However, final section 15.40(b)(1)(iii) requires deduction of “Deferred tax assets, net of valuation allowances”, without limiting the deduction to those sources. This discrepancy between the reporting-form description and the governing capital rule requires clarification from the OCC before the capital calculation is implemented. Item 3 also picks up digital assets reported on the gas-fee line that meet the US GAAP definition of an intangible asset, so that token balance can reduce capital.

Section 15.41(b) requires operational-backstop assets equal to 12 months of total expenses. Eligible assets comprise US coins and currency or Federal Reserve Bank balances; demand deposits or funds in share accounts payable on demand at a US insured depository institution, with balances fully insured by the FDIC or National Credit Union Administration; and Treasury bills, notes or bonds with a remaining maturity of 93 days or less or issued with a maturity of 93 days or less. These assets must be separately identified from stablecoin reserve assets and the issuer’s other assets.

Item 11 calculates the operational-backstop requirement using the relevant expenses for the current and three preceding quarters. Where quarterly PS-02 reports are unavailable, section 15.41(b)(1)(ii) requires actual expenses for quarters in which the issuer operated and reasonably determined expenses for other quarters. In addition, section 15.41(b)(1)(iv) requires an issuer that acquires another permitted payment stablecoin issuer to add the acquired issuer’s historical expenses to its own historical expenses. One-time expenses wholly unrelated to continuing operations are excluded only with prior written OCC approval.

Item 9 reports qualifying operational-backstop debt under section 15.40(c), capped in aggregate at 50 percent of the operational-backstop requirement. Each instrument must satisfy the rule’s conditions, including issuance and payment, subordination, unsecured status, a minimum maturity of at least five years and no direct or indirect affiliate funding. At the beginning of each of the last five years of the instrument’s life, the maximum eligible amount declines by 20 percent per year of the otherwise full qualifying amount, and an instrument with less than one year of remaining maturity is excluded entirely. The instructions place it in balance sheet item 14, subordinated notes and debentures, where applicable. Item 10 nets that debt off the backstop assets, and the equity-funded remainder is the item 5 deduction.

Item 12 reports the issuer’s minimum capital requirement under section 15.41(a), including the $5 million minimum and any higher requirement applicable to the issuer. Separate from the quarterly filing deadline, section 15.41(c)(1)(i) requires a permitted payment stablecoin issuer to notify the OCC within 24 hours if it fails to meet either its minimum capital or operational-backstop requirement during a quarter. Section 15.41(c)(1)(ii) also requires the issuer to report publicly, through its quarterly report under section 15.14(i), whether it complied with both requirements during the quarter. A de novo issuer, approved within the prior three years or a State qualified issuer transitioned within that period without a waiver, holds the greater of its licensing or chartering condition amount and $5 million for 36 months unless a different period is set. The notice states that FPSIs would not complete Schedule D because they are outside the subpart E capital requirements.

Signatures, publication and confidential treatment

Each PS-02 carries two layers of sign-off under section 15.14(i)(2) and (3). The chief financial officer, or the person performing that function, declares the report true and correct to the best of their knowledge and belief. All other directors and senior management attest that they have examined it and that it is true and correct to the best of their knowledge and belief. The OCC refused requests to let another executive sign or to limit attestation to three directors, saying a single accountable member of senior management should own financial reporting.

Publication is the default. All PS-02 schedules, including the optional narrative statement in item 21, are posted on occ.gov once submitted, accepted and prepared for publication. A confidential treatment request must be made in writing before submission, identify the specific items, justify the request and show the specific harm public release would cause; merely stating competitive harm is not sufficient, and the OCC expects to grant such requests sparingly. PS-01 is confidential in full, its forms and schedules described as OCC property whose unauthorized disclosure is prohibited under 12 CFR 4.37.

Call Report overlap, data standards and the specifications still to come

Commenters asked the OCC to let Call Report filers skip PS-02, or to let PS-02 replace the Call Report for banks mainly issuing stablecoins. The OCC kept both, saying the Call Report shows a bank’s financial condition and PS-02 a PPSI’s. In the final rule preamble the OCC anticipates that reserve assets will generally be recorded on the issuer’s GAAP balance sheet and included in the section 15.14(i) quarterly report and on Call Report Schedule RC for a parent insured national bank or Federal savings association. On that expectation, the same reserve assets of a bank-owned issuer appear in two quarterly filings: the subsidiary’s PS-02 and the parent’s FFIEC Call Report.

The format is still open. The forms are published as Excel workbooks with PDF instructions, and the OCC expects to collect data in XML or another format. Before implementing the final rule it will publish technical specifications with a data dictionary, edit checks, XML schemas, sample XML files and filing instructions, and it says the forms will be consistent with the Financial Data Transparency Act joint data standards issued in June 2026, although its own agency-specific adopting rule has not been issued.

What changed from the June 2026 proposal

The revised burden table estimates 39 permitted payment stablecoin issuer respondents for ongoing weekly and quarterly reporting, plus one foreign payment stablecoin issuer respondent. For the 39 PPSIs, the estimates are 2 hours per weekly PS-01 response and 16 hours per quarterly PS-02 response. The total estimated annual burden is 10,458 hours, comprising 3,825 hours of initial setup and 6,633 hours of ongoing compliance. The OCC kept the weekly figure low because it expects issuers’ real-time controls over issuance and 1:1 reserve backing to generate much of the data.

Frequently Asked Questions

What happens if OMB has not approved the collection by 25 January 2027?

Neither the bulletin nor the notice addresses that case. Both present the January and March report dates as subject to OMB approval, and the notice restates the Paperwork Reduction Act rule that a respondent is not required to respond to a collection that does not display a currently valid OMB control number; the collection is still listed as 1557-NEW. Section 15.14(h), effective 18 January 2027, separately requires weekly reporting in the manner and form the OCC specifies, so the interaction would need confirmation from the OCC at the time.

We find a significant error in a PS-01 filed three weeks ago. Is there still a correction deadline?

The fixed five-day window is gone, but the instructions still require an amended report whenever the issuer or the OCC discovers significant errors or omissions, and the OCC said removing the deadline does not relieve issuers of timely correction. Where the OCC’s interpretation of an instruction differs from the issuer’s, it may also require earlier reports to be amended.

A State qualified issuer transitions to Federal oversight in August. What period does its first PS-02 income statement cover?

Calendar year to date. The Schedule A instructions state that an entity that transitioned to federal oversight reports year-to-date income and expenses regardless of the transition date, while one that began operating during the year reports everything since it started. For Schedule E quarterly averages, an entity that began operating mid-quarter counts only its operating days, in numerator and denominator.

Do tokenized Treasuries or tokenized deposits need their own reserve category?

They stay within the underlying category, with the tokenized balance in Schedule B, Column F, and a Y/N indicator on the instrument line in Schedules C to G. The OCC added the indicators after a commenter argued that a tokenized claim can trade away from the value of the asset it references; the OCC points to possible operational, market or liquidity differences between tokenized and non-tokenized assets.

The section 15.2 definition establishes the meaning of tokenized form, but does not independently make an instrument an eligible reserve asset. Section 15.11(b)(8) permits tokenized forms of the assets described in paragraphs (b)(1) through (3), (b)(6) and (b)(7), provided they comply with applicable laws and regulations. It does not extend this permission to the repurchase and reverse-repurchase arrangements in paragraphs (b)(4) and (b)(5). A tokenization indicator in a reporting schedule does not expand the permissible reserve-asset categories.

Does a registered foreign issuer complete the PS-02 capital schedule?

The notice states that FPSIs would not be required to complete Schedule D because they are not subject to the subpart E capital requirements. The PS-02 general instructions describe every OCC-supervised PPSI and FPSI as a reporting entity without carving out Schedule D, so the treatment is one to confirm with the OCC, for example alongside any exemption request under section 15.31(b)(2)(ii).

Related Articles

• FR UU Reporting: The Fed’s New Stablecoin Collection and FR Q Changes: the Federal Reserve’s proposed GENIUS Act collection for Board-supervised issuers, with comments due 30 November 2026.
• FFIEC Call Report: Who Files 031, 041 or 051 for 30 September 2026: which Call Report form a US bank files and the quarter’s changes.
• MiCAR Reporting Obligations for CASPs: Complete Implementation Guide: the EU crypto-asset framework’s capital, record-keeping, white paper, AML and market abuse duties.
• Hong Kong Stablecoins Ordinance: HKMA Grants the First Issuer Licences: Hong Kong’s first licensed stablecoin issuers and their reserve, redemption and reporting duties.
• USDC Significant E-Money Token: Dual Supervision From 12 November: how the EBA’s significance classification of USDC moves supervision of its EU issuer.

Key Takeaways

• Comment on the revised forms by 23 November 2026, by email to prainfo@occ.treas.gov or through reginfo.gov, including “OCC” and “1557-NEW”.
• Count stablecoins before counting forms: each payment stablecoin needs its own Wednesday PS-01, and on my reading that includes white-label coins the entity is legally responsible for redeeming.
• Cut every daily figure at 11:59:59 p.m. Eastern, weekends included, from the week ending Monday 25 January 2027.
• Re-test Monday-only eligibility every week against enforcement status, affiliated issuance under $1 billion and compliance with sections 15.11 and 15.14.
• Line up the CFO declaration and every director and senior manager attestation for the 31 March 2027 PS-02, due by 30 April 2027.
• Lodge any PS-02 confidentiality request in writing, item by item, before submission.

Sources and References

• GENIUS Act, Public Law 119-27 (18 July 2025): govinfo
• OCC Bulletin 2026-52, revised reporting forms (21 October 2026): occ.gov
• OCC forms notice, 91 FR 66916 (23 October 2026): Federal Register; OCC PDF
• Instructions for OCC Reporting Form PS-01 (21 October 2026): PDF; form: XLSX
• Instructions for OCC Reporting Form PS-02 (21 October 2026): PDF; form: XLSX
• OCC final rule, 12 CFR part 15, 91 FR 67000 (23 October 2026): Federal Register; OCC PDF
• OCC Bulletin 2026-50, GENIUS Act Regulations: Final Rule (21 October 2026): occ.gov
• OCC News Release 2026-92 (21 October 2026): occ.gov
• OCC Bulletin 2026-24 (11 June 2026): occ.gov; 91 FR 35795 (12 June 2026): Federal Register
• OCC GENIUS Act page: occ.gov
• FDIC FIL-38-2026 (17 July 2026): fdic.gov
• Federal Reserve Board GENIUS Act proposal, 91 FR 61580 (29 September 2026): Federal Register

Preparing for the 27 January 2027 first weekly filing

Three outputs carry the work between now and January: a per-stablecoin daily data set cut on Eastern time for PS-01 Schedules A to G, a GAAP quarter-end close that produces PS-02 with its capital and backstop calculations, and a signature process that reaches every director and senior manager. The OCC’s technical specifications, with the XML schemas and edit checks, are the remaining dependency, and the OCC has said it will publish them before the rule is implemented. Comments on the forms are due on 23 November 2026; the first weekly file is due by 5:00 p.m. Eastern on Wednesday 27 January 2027.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.