2025 Supervisors Symposium

StablecoinState SupervisoryConsiderations

Legal, Regulatory and Enforcement Powers of Federal and State Regulators over PSCs

FEDERAL

STATE

SOURCE

No, except State issuers by home State (< $10B unless federal waiverprovided)

GENIUS Act

Yes

No re PSC Issuer. Per16(d), norefiatmoneytransmissionactivities by State uninsured bank sub PSC issuer

State Money Transmission Licensing

n/a

General anti-fraud enforcement authority

Yes

Yes

Federal UDAAP

???

Maybe?

State UDAP/UDAAP

n/a

Maybe?

RegE Electronic Fund Transfers

???

???

Reg DD Truth in Savings

n/a

n/a

Reg I “NDIP” Disclosure Requirements for Depository Institutions Lacking Federal Deposit Insurance

n/a

n/a

Securities registration laws

No

No

Lending, credit, debt collection, securities laws and regulations generally are not applicable

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