The FDIC published its prudential framework for permitted payment stablecoin issuers in the Federal Register on April 10. FinCEN and OFAC published a joint anti-money laundering and sanctions compliance rule on the same day. The OCC, NCUA, and Treasury Department have all issued their own proposals since February. The Federal Reserve Board has not published its notice of proposed rulemaking, making it the sole primary prudential regulator without a GENIUS Act proposal.
The FDIC framework requires issuers to maintain 1:1 reserve backing in eligible assets including US currency, Federal Reserve balances, insured deposits, and short-term Treasuries. Stablecoins must be redeemable within two business days. Issuers must hold a separate 12-month operating expense liquidity buffer distinct from the reserve pool. No single eligible financial institution may hold more than 40 percent of an issuer's reserves. Reserve deposits at insured depository institutions are classified as corporate deposits of the issuer. FDIC insurance for those deposits is capped at the standard $250,000 limit. Pass-through coverage to individual stablecoin holders is not available.
The FinCEN-OFAC rule designates all permitted payment stablecoin issuers as financial institutions under the Bank Secrecy Act. The rule requires comprehensive anti-money laundering programs and sanctions compliance. Comment periods for the FDIC and FinCEN-OFAC proposals close on June 9. The GENIUS Act takes effect on the earlier of January 18, 2027, or 120 days after all final regulations are issued.