Summary
Six federal agencies missed the July 18, 2026 GENIUS Act rulemaking deadline. The core blockage is a Fed-OCC dispute over reserve composition (T-bills only vs. including commercial paper). A secondary FDIC bottleneck involves unresolved capital surcharge treatment for stablecoin deposits. The 2028 compliance cliff remains fixed, effectively shortening the runway for issuers. Three signals to watch: a Fed-OCC joint statement narrowing the dispute, FDIC guidance on stablecoin deposits, and congressional hearings.
Key Points
- Reserve dispute: Fed (Barr) wants T-bills under 90 days + central bank deposits; OCC wants to include short-term commercial paper
- FDIC bottleneck: no guidance on how stablecoin deposits affect bank capital surcharges; banks avoid the business
- 10 NPRMs issued: Treasury (4), OCC (2), FDIC (1), NCUA (1), joint interagency (1), joint CIP (1)
- Effective date: January 18, 2027 (or 120 days after final rules)
- 2028 cliff: non-compliant stablecoins banned from U.S. exchanges; deadline has not moved
- Circle impact: cannot pitch federal certification to corporate treasuries
- Tether impact: keeps expanding offshore market share unopposed
- Market growth: stablecoin supply up 18.6% to $308-310B since GENIUS passage
- Three signals to watch: Fed-OCC joint statement, FDIC guidance, congressional hearings
- Issuer response: mid-sized issuers exploring parallel registration in Singapore or UAE