The Federal Reserve's GENIUS Act stablecoin rules, proposed on 24 September 2026, finish the federal set. The OCC, FDIC, NCUA and Treasury had already published their proposals, so a US issuer can now compare all three federal supervisory routes on paper before choosing a charter or a bank partner. For most founders, the practical message is that capital, not reserves, is where the routes will differ.
Reserves were always going to be one-to-one: the Act says so. What the Fed adds is a capital stack on top, a hard two-business-day redemption standard, and a mechanism that forces wind-down if capital stays short. If you are weighing a bank-owned issuer against a non-bank route, the numbers below belong in the model now, even though they are still proposals.
What the Fed proposed on 24 September 2026
The Board published two proposals. The first sets reserve, capital, risk-management, custody and permitted-activity standards for stablecoin issuers it supervises. The second creates an application process for state member banks that want a subsidiary to issue payment stablecoins.
According to the Board's staff memo:
- Reserves at least 1:1, in cash, Federal Reserve balances, demand deposits or Treasuries maturing in 93 days or less.
- Redemption within two business days.
- Operational-risk capital of 2% on the first $20bn of stablecoins outstanding, 1.5% on the next $30bn and 1% above $50bn.
- Reserve-quality charge of 2% on uninsured deposits and undercollateralised repos held as reserves.
- Wind-down trigger: a capital shortfall lasting two consecutive quarters requires the issuer to liquidate reserves and redeem outstanding coins.
State-qualified issuers that pass $10bn outstanding move to federal supervision, and the memo sets an initial examination within six months of that transition.
How do the GENIUS Act stablecoin rules change licensing choices?
Three things stand out for anyone planning a US issuance.
The tiered charge favours scale, but the floor is real
A 2% charge on the first $20bn is material for a new issuer running on thin reserve yield. Larger issuers get a lower marginal rate, which tilts the economics towards incumbents and bank-affiliated issuers with existing capital. A start-up should model the capital line before choosing between a state route and a federal one.
Redemption speed is now an operating commitment
Two business days is a treasury and banking-partner question as much as a legal one. Your reserve custodians and settlement rails need to support it on a bad day, not just on an average one.
The clock is fixed by statute
The Act takes effect on the earlier of 18 January 2027 or 120 days after final rules. With the Fed proposal carrying a 60-day comment period from Federal Register publication, final rules from every agency are unlikely to land much before that statutory date. Build the plan around January.
Governor Barr's separate statement flagged run risk and questioned the "significant or systemic" threshold before the Fed can act on AML failings. Expect both points to feature in comments.
Where this leaves US crypto licensing
Stablecoin issuance is one strand of US licensing. State money transmission and the unresolved market-structure bill still decide most exchange and custody models. Our United States crypto licensing profile tracks the state and federal picture, and the crypto licensing comparison sets the US against MiCA, Hong Kong and Singapore routes side by side. For a fuller written view, see our regulatory reports.
Sources
- Federal Reserve press release, 24 September 2026
- Federal Reserve Board staff memo on the GENIUS Act proposals
- Statement by Governor Michael S. Barr, 24 September 2026
Informational only, not legal advice. Figures are from the Board's proposals as published on 24 September 2026 and may change before final rules.