Fed proposes reserve and capital rules for GENIUS Act stablecoins
The Federal Reserve Board on Thursday requested public comment on two proposed rules that would govern how Board-supervised banks issue payment stablecoins under the GENIUS Act. One proposal sets reserve, capital and risk management standards; the other creates the application process a bank must follow to get approval to issue a stablecoin.
- Reserve rule requires full backing with Treasury bills and other high-quality liquid assets
- Application rule requires a business plan, financial information, and creates an appeals process
- Comment period runs 60 days from Federal Register publication, no date yet set
The release lays out the Fed’s first concrete attempt to write supervisory rules for payment stablecoins since the GENIUS Act became law. It covers only banks and bank subsidiaries that fall under the Board’s supervision, not the nonbank or state-chartered issuers that answer to other regulators under the same statute.
Reserve and Capital Standards
The first proposal would force Board-supervised issuers to fully back stablecoins with permissible reserve assets. The Fed’s release states it plainly:
“The first proposal would require that Board-supervised payment stablecoin issuers fully back their stablecoins with certain permissible reserve assets, such as short-term Treasury bills and certain other high-quality, liquid assets.”
Federal Reserve press release, September 24, 2026
The same proposal adds standardized capital requirements for credit and operational risk, plus custody rules for firms that safekeep the reserve assets. It also clarifies which stablecoin-related activities Board-supervised banks may conduct.
Application Process for Bank Subsidiaries
The second proposal builds the on-ramp: a tailored approval process for a Board-supervised bank that wants a subsidiary to issue payment stablecoins. Applicants submit a business plan and financial information among other documents.
The proposal also sets procedures for appeals, hearings and final determinations for applications. No specific timeline for reviewing applications is given.
What the Release Leaves Open
The document does not name a single bank, applicant or effective date beyond the 60-day comment window. It does not state capital ratio numbers, a list of permissible reserve assets beyond Treasury bills, or how this framework interacts with OCC or state-level GENIUS Act tracks for nonbank issuers.
It also does not say when the rules would take effect after the comment period closes, or whether stablecoins already circulating from bank issuers would need to convert reserves before a compliance deadline.
The CCS Read
The CCS read. Full reserve backing and standardized capital rules push bank-issued stablecoins toward something closer to narrow-bank economics, which squeezes yield issuers could otherwise offer holders. The tailored application process, with its appeals and hearings track, signals the Fed expects contested cases, likely from banks racing to claim GENIUS Act legitimacy before nonbank rivals do.
Watch the Federal Register for the official publication date of both notices, which starts the 60-day comment clock.
