Two proposals enter consultation
The Federal Reserve opened consultations on two stablecoin proposals on 24 September 2026. One covers the operating framework for supervised issuers; the other concerns applications by banks seeking to issue through subsidiaries. Both implement parts of the GENIUS Act and remain proposals rather than final rules. Comments are due 60 days after publication in the Federal Register; the press release itself does not set a calendar deadline.
Reserves and capital serve different purposes
The accompanying staff memorandum describes reserves that would be segregated from other issuer assets and sufficient to cover outstanding stablecoins at their face value. Permitted categories include specified cash holdings and short-term Treasury instruments. The proposal also addresses capital for operational risk and certain credit exposures, alongside technology security and risk management. These are distinct safeguards: reserve backing concerns the assets supporting redemption, while capital addresses losses from the issuer’s activities. The memorandum is dated 3 September and was published with the later announcement; it is supporting material, not a second new decision.
What an applicant would need to provide
The application proposal concerns insured state member banks that want a subsidiary to issue payment stablecoins. According to its staff memorandum, an application would include a business plan, financial information, relevant policies and procedures, documentation of the proposed capital structure, biographical reports and certifications. The proposed process also covers appeals, hearings and final determinations. This is a description of how an application would be assessed. It does not identify a newly approved token, establish that a particular bank has received authorization, or remove the need for the proposed subsidiary to satisfy the applicable requirements.
A complete application starts the decision clock
The detailed application notice explains a 120-day decision period after receipt of a substantially complete application. Completeness therefore matters as much as the initial filing date. A material change, such as a deterioration in financial condition, a changed business plan or a changed ownership structure, can make earlier information insufficient. Supplementary information may then lead to a new submission date and restart the clock. Readers should distinguish this proposed application timetable from the separate public comment window; neither is a promised commercial launch date for a stablecoin product.
Barr highlights questions still to be resolved
Governor Michael Barr supported the rulemaking as a step toward reliable payment instruments, while emphasizing redemption at face value during stress. His statement calls for public input on reserve restrictions, capital treatment, interest-rate and foreign-currency risks, and clear redemption rights. He also expressed concern about a proposed threshold for supervisory action on anti-money-laundering deficiencies. These are attributed views within the consultation. They show which issues remain contested and should not be presented as additional final requirements already imposed on every stablecoin issuer.
HOSTuvo INTERPRETATION
HOSTuvo interpretation: the consultation is relevant to payment infrastructure and issuer risk. It does not establish a price direction for Bitcoin or any stablecoin, and it does not authorize a trade. Track the final rules, the issuer’s actual reserves and redemption arrangements separately.
