Woofun AI reports that the GENIUS Act restricts payment stablecoin issuance in the United States to permitted entities, excluding those outside this category. The OCC's February proposal outlines broad implementation rules for national bank subsidiaries, federal savings associations, foreign issuers, and nonbank entities seeking qualified status. Issuers must satisfy BSA, OFAC, and lawful-order requirements before an operating framework is established. Foreign issuers face additional barriers, requiring reciprocal arrangements and Treasury rules within one year of enactment. The OCC details registration, rejection, appeals, and rescission processes for foreign issuers under its jurisdiction. State equivalence remains uncertain if federal, Treasury, and OCC rules are incomplete. Issuers most exposed include new federal applicants, foreign issuers seeking US availability, and state-qualified issuers relying on equivalence. If July 18, 2026, arrives without coherent rules, these entities will face immediate consequences.