Full reserve backing, capital rules and a bank approval path under the GENIUS Act. Here's what the proposal actually says, and what it doesn't.
🏛️ A stablecoin looks simple. One token, one dollar. The rulebook behind it just got a lot more detailed.
On Thursday, September 24, the Federal Reserve Board asked the public for comment on two proposals. Together they turn the GENIUS Act, the stablecoin law signed in July 2025, into specific rules for the issuers the Fed supervises.
📋 Here's what the first proposal says.
Issuers would have to back every token fully with approved reserve assets. Think short-term Treasury bills and other high-quality, liquid assets. According to the Fed's staff memo, that includes cash, balances at the Fed, insured deposits, and Treasuries maturing within 93 days. The proposal also adds standard capital requirements, risk management standards, and rules for the firms that hold the reserves.
🏦 Here's what the second proposal says.
It creates an application process for banks that want to issue payment stablecoins. Applicants would submit a business plan and financial information, and the process includes appeals and hearings. An insured state member bank would need Fed approval before a subsidiary could issue stablecoins.
⚠️ Now the part most headlines skip.
This is a proposal, not a final rule. The 60-day comment period only starts once the notices are published in the Federal Register, and the rules can still change. It also applies to issuers under the Fed's supervision, so whether a specific stablecoin is covered depends on who issues it. And a payment stablecoin under these rules would not become an insured bank deposit.
🧠 Why does it still matter?
Because it is one piece of a bigger rollout. The OCC is reportedly racing to finalize its own rules by November, ahead of a January deadline in the law. The Treasury has separately proposed rules that would bar platforms from selling noncompliant stablecoins to US customers.
Put together, the direction is clear. Stablecoins are being pulled inside the regulated financial system, and banks are being given a formal path in. It fits what you have seen elsewhere this month, from the ECB's Pontes launch to the UK bank tokenized deposit pilot and the US Clearing House network. Banks are building their own digital money.
✅ What this means for you
If you hold stablecoins like $USDC, nothing changes today. But it is worth knowing that clear reserve rules are meant to make the "is it really backed?" question easier to answer over time.
If you park funds in stablecoins on exchanges, watch which tokens end up compliant once the rules are final. Platforms may have to stop selling ones that are not, so your choice of stablecoin could matter more than it does now.
If you follow tokenization and bank adoption, this is a signal, not a trade. It shows regulators building the road that bank-issued digital money will run on.
🟢 Bullish scenario
Clear, consistent rules give banks and large institutions the confidence to enter, more compliant stablecoins launch, and the whole category grows on firmer ground.
🔴 Risk scenario
Strict requirements raise costs and push smaller issuers out, final rules from different agencies do not line up, and the timeline drags on.
👀 Three things to watch
1️⃣ Federal Register publication
When does the 60-day comment window actually open, and what do issuers and banks push back on?
2️⃣ The OCC's final rules
Does the November target hold, and do its rules match the Fed's approach?
3️⃣ First bank applications
Which banks apply first once the process is final?
💡 The key takeaway
This is not the end of the stablecoin story. It is the rulebook being written in public.
The proposal sets a high bar on reserves and opens a door for banks, but nothing is final yet. The real question is whether the finished rules make stablecoins safer and easier to use, or simply narrower and more expensive.
That is the part worth watching.
This post is for informational and educational purposes only and is not financial advice. Crypto markets are volatile. Always conduct your own research before making financial decisions.
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