Fed opens stablecoin rulebook for comment
The Fed's GENIUS Act proposals set full-reserve rules and a bank application path for stablecoin issuers it supervises.

The Federal Reserve opened two rulemakings on September 24 under the GENIUS Act. One sets reserve and capital standards for stablecoin issuers it supervises. The other builds an application process for banks that want to issue their own tokens.
Both are comment-period proposals, not final rules. But they draw the first hard lines around who gets to issue a dollar-pegged token inside the regulated banking system, and what they have to hold against it.
The reserve mandate
The core requirement is simple to state and hard to game: full backing with safe, liquid assets. No fractional reserves, no yield-bearing side bets counted as collateral.
The numbers in the filing show how tight the Fed wants this drawn:
- The Fed opened public comment on two GENIUS Act proposals on September 24, 2026, per Decrypt.
- One proposal covers reserve and capital rules for issuers under Fed supervision.
- The second creates a formal bank application track for stablecoin issuance.
- GENIUS Act, the enabling statute, passed in 2025 and set up federal oversight of payment stablecoins.
Who actually applies
The default read is a compliance story: stablecoins finally get bank-grade guardrails. That's true, but it undersells who benefits.
A formal application process is a moat for anyone who can staff a legal team and clear capital thresholds. Small issuers can't.
Banks that already hold trust charters, custody relationships and balance sheets built for capital rules gain a straight lane into stablecoin issuance. That's the incumbents.
Non-bank issuers face a choice: partner with a supervised bank, or stay outside the perimeter and lose access to the customers and rails that come with Fed sign-off.
The full-reserve requirement compounds this. Safe-asset backing at scale costs money to source and custody.
Firms with existing Treasury desks and repo access absorb that cost more easily than a startup building reserve management from scratch. The proposals don't ban competition. They price it.
What confirms the read
The comment period is where this either narrows or widens. Watch who shows up and what they ask for.
- The comment period's length and close date, once the Fed publishes it in the Federal Register.
- Whether large banks (JPMorgan, Citi, regional trust banks) file applications in the first cohort versus fintech issuers.
- Any capital ratio or liquidity coverage threshold the final rule sets, and whether it tracks existing bank capital rules or sets a separate bar.
