2025 Supervisors Symposium

GENIUSAct: Key Elements

WHO CAN BECOME AN ISSUER?

PREEMPTION/PASSPORTS:

Federal issuers : l icensed, regulated, examined, and supervised exclusively by the Comptroller State Issuers : • host State laws, inc. laws relating to consumer protection, only apply to the activities to the extent they would apply to the activities conducted in the host State by an out-of-State Federal qualified payment stablecoin issuer • host State laws governing the chartering, licensure, or other authorization to do business are n/a

Uninsured national bank

IDI subsidiary

July18, 2025

GENIUS Act signed into law

U.S. federal branch of an FBO

Federal Agency deadline to issue final rules ( 1 year after enactment)

State-licensed PSC issuer (<$10B)

July ‘26

Options

Nov ’26 - Jan ‘27

GENIUS Bill takes effect (18 months after enactment)

Federal licensed non-bank entity (e.g., national trust charters)

Sales of PSCs by non-permitted issuers prohibited (3 years after enactment)

Foreign stablecoin issuer

July ’28

KEY AREAS COVERED IN THE GENIUS ACT

Transparency Issuers must regularly publish reports on their stablecoins (e.g., underlying assets).

Foreign Issuers Only comparable regulatory regimes may issue PSCs in the U.S..

Charter and Regulation Clear guidance on regulatory oversightand typesofcharter options.

Reserve Requirements Issuers must Maintain 1:1 reserve backing among multiple assets.

Notable Regulations PSCs issued under this framework areexempt fromsecurities law.

Future Standards Capital, liquidity, interest rate, risk management & AML standards.

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Federal Interaction with State Programs

Federal Certification:

State programs must be certified by the Stablecoin Certification Review Committee (SCRC) as “substantially similar” to the federal framework established by the GENIUS Act within 1 year of the Act’s effective date (no later than Jan. 18, 2028) and recertified annually.

Federal Coordination & Oversight:

States must share information on state

State issuers with $10bn or more in outstanding issuance transition to co-regulation with the state and a federal regulator (either FRB or OCC) unless waived by federal regulator

States can opt into an MOU with the FRB to co-regulate all state issuers

FRB and OCC (for nonbanks) have exigent enforcement authority over state issuers

qualified issuers with the FRB (including application and throughout life of the entity)