The GENIUS Act proposed rules arrived in stages between December 2025 and September 2026. The statute, Public Law 119-27, was enacted on July 18, 2025. It gave regulators one year to write implementing regulations and set its own effective date as the earlier of 18 months after enactment or 120 days after final regulations are issued. The Treasury now describes January 18, 2027 as the expected effective date.
A bank does not need to read every docket. It needs to know which agency will supervise its stablecoin subsidiary, what that agency has proposed, and what can be prepared before the text is final. This guide is organized that way.
Start with your primary regulator
Under the Act, a bank issues a payment stablecoin through a subsidiary that its regulator has approved as a permitted payment stablecoin issuer. The regulator of the subsidiary is the appropriate federal banking agency of the parent bank.
| If your bank is a | Read first | Published |
|---|---|---|
| National bank or federal savings association | OCC notice of proposed rulemaking, Bulletin 2026-3 | February 25, 2026. Federal Register March 2, 2026 |
| State nonmember bank or state savings association | FDIC application procedures (FIL-59-2025) and requirements and standards (FIL-11-2026) | December 16, 2025 and April 7, 2026 |
| State member bank | Federal Reserve Board, two proposals on standards and on applications | September 24, 2026. Federal Register September 29, 2026 |
| Any charter | Treasury proposal on what it means to issue, offer or sell a payment stablecoin in the United States | August 17, 2026 |
State-chartered banks should also check their state regulator's position. The Act allows smaller issuers to operate under a state regime that is substantially similar to the federal one, and the Treasury has published principles for making that comparison.
What the proposals have in common
The agencies are implementing the same statute, so the core obligations repeat from one docket to the next.
- Reserves. Outstanding stablecoins must be backed at least one to one by identifiable reserves in the asset types the Act permits, such as cash, deposits, short-dated Treasury bills and certain repurchase agreements and money market funds.
- Redemption. Issuers must publish a redemption policy and honor it. The FDIC proposal would require redemption within two business days.
- Capital and risk management. Each agency proposes standards tailored to the size and complexity of the issuer. The Federal Reserve proposal includes standardized capital requirements addressing credit and operational risk.
- Reporting. The Act requires a monthly report on reserve composition, examined by a registered public accounting firm and certified by the chief executive and chief financial officers.
- Financial crime compliance. Issuers are treated as financial institutions under the Bank Secrecy Act. The OCC published its anti-money laundering and sanctions proposal on June 22, 2026 (Bulletin 2026-28), and the FDIC's own Bank Secrecy Act and sanctions compliance proposal appeared in the Federal Register on June 5, 2026.
- Custody. Each proposal sets standards for safekeeping reserve assets and customer property.
What is specific to each agency
OCC. The proposal reaches beyond bank subsidiaries. It covers nonbank federal qualified issuers, foreign issuers under OCC jurisdiction, and certain custody activities of OCC-supervised entities. Comments were due 60 days after Federal Register publication.
FDIC. The April proposal is the one that addresses deposit insurance. It states that reserves backing a stablecoin would not be insured to holders on a pass-through basis, and that insurance on deposits, which applies subject to ownership category and limits, does not depend on the technology used to record them. We cover the consequences in are tokenized deposits FDIC insured.
Federal Reserve. The Board issued two proposals together. One sets reserve, capital and risk management standards and adds rules for Board-supervised firms that safekeep the assets backing stablecoins. The other creates an application process, including business plans, financial information, appeals and hearings. Comments are due 60 days after the September 29 publication, which puts the deadline in late November 2026.
Treasury. The August proposal implements section 3 of the Act. It defines when a person is issuing a payment stablecoin in the United States and therefore needs a license, and it addresses the restriction that takes hold on July 18, 2028, when digital asset service providers may no longer offer or sell stablecoins from issuers that are not permitted.
The application path for a bank
Section 5 of the Act sets the outline. The bank applies to its regulator on behalf of the subsidiary. The regulator must decide within 120 days of receiving a substantially complete application, and an application is deemed approved if no decision is rendered in that time.
The FDIC's application proposal shows what "complete" is likely to mean in practice. It asks for the policies, procedures and customer agreements that govern custody and safekeeping, segregation of customer and reserve assets, recordkeeping, reconciliation and transaction processing, redemption, and Bank Secrecy Act and sanctions compliance. A bank that has those documents drafted before the rule is final will be ahead of the queue.
What to prepare before the rules are final
- Confirm the instrument. A bank that only wants programmable money for its own customers may not need a stablecoin subsidiary at all. A tokenized deposit stays inside existing deposit law.
- Name the docket owner. One person in legal or compliance should track your regulator's docket and report changes to the board.
- Draft the application file. Reserve policy, redemption policy, custody arrangements, reconciliation and the financial crime program can all be written against the proposed text and adjusted later.
- Decide how supply will be controlled. A design that mints only after funding is confirmed and burns at redemption makes the monthly reserve examination a matter of matching two numbers. That is how our Regulated Money Platform works.
- Run vendor diligence early. The bank stays responsible for what its providers do. Our security and compliance overview is written for that review.
For the board-level view of the same subject, see what banks should prepare before January 2027. To work through your own charter's path, schedule a session with us.
Frequently asked questions
Are the GENIUS Act rules final?
The core rules discussed here were published as proposals: the OCC in February 2026, the FDIC in December 2025 and April 2026, the Treasury in August 2026 and the Federal Reserve in September 2026. Each is subject to public comment and may change. Check your regulator's docket for final text before relying on any specific requirement.
Which regulator supervises a bank's stablecoin subsidiary?
The appropriate federal banking agency of the parent bank. For a national bank or federal savings association that is the OCC. For a state nonmember bank it is the FDIC. For a state member bank it is the Federal Reserve Board. Each agency has published its own proposal for the issuers it will supervise.
When does the GENIUS Act take effect?
The Act takes effect on the earlier of 18 months after its enactment on July 18, 2025, or 120 days after the primary federal regulators issue final implementing regulations. The Treasury refers to January 18, 2027 as the expected effective date. A separate restriction on offering stablecoins from issuers that are not permitted begins July 18, 2028.
How long does a regulator have to decide on an application?
Under section 5 of the Act, the regulator must render a decision within 120 days of receiving a substantially complete application. If it does not, the application is deemed approved. The practical work is reaching "substantially complete", which means having policies for reserves, redemption, custody, reconciliation and financial crime compliance ready.
Does a bank need a stablecoin subsidiary to offer tokenized money?
Not necessarily. The Act's definition of payment stablecoin excludes deposits, including deposits recorded using distributed ledger technology. A bank can offer a tokenized deposit to its own customers under existing deposit law. A subsidiary approved as a permitted issuer is needed only when the bank wants to issue a payment stablecoin.
This article is general information, not legal advice. Proposed rules change before they are final. Consult your counsel on how the GENIUS Act and your regulator's rules apply to your charter.