In an opinion piece for Kelman Law, Michael Handelsman says a payments company considering a branded dollar stablecoin must decide which legal entity will owe holders dollars when they redeem. The company could seek approval to issue the token itself or partner with an issuer; putting its name on a partner’s token would not make it the issuer or remove the need to assess its own licensing obligations.
Handelsman says the prior-approval requirement generally begins January 18, 2027, and that the OCC was not yet accepting applications or waiver requests as of November 10. A pending application is not permission for a new entrant to launch. He says agreements with partner issuers should spell out who can mint tokens, how holders redeem them, and who handles failed payments and outstanding tokens if the partnership ends.
