Federal Reserve Seeks Comment On Stablecoin Capital And Redemption Rules After Missing GENIUS Act Deadline

The Federal Reserve requested public comment on two stablecoin issuer proposals on September 24, 2026, after all five implementing agencies missed the GENIUS Act's July 18, 2026 rule-making deadline. The Board of Governors published the paired rule packages to establish the regulatory framework for Board-supervised payment stablecoin issuers under the Guiding and Establishing National Innovation for U.S. Stablecoins Act, signed into law on July 18, 2025.

The proposals arrive more than one year after the statute was enacted and roughly two months after the statutory deadline for final rules passed without a single agency publishing a final rule. The Fed's action follows proposals already issued by the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Treasury Department, each of which remains in comment or proposal stage as of late September 2026.

The core series of Fed figures:

  • 2 proposals — the number of rule packages the Federal Reserve Board published for public comment, as of September 24, 2026
  • July 18, 2026 — the statutory deadline for final implementing rules under the GENIUS Act, which all five agencies missed
  • January 18, 2027 — the unchanged effective date of the GENIUS Act, regardless of the missed rule-making deadline
  • 1 year — the period between the GENIUS Act's signing on July 18, 2025 and the missed July 18, 2026 rule-making deadline

Federal Reserve Requests Comment On Two Stablecoin Proposals One Year After GENIUS Act Signing

The Federal Reserve Board's two proposals implement the GENIUS Act's directive to treat permitted payment stablecoin issuers, or PPSIs, as financial institutions under the Bank Holding Company Act. The first proposal would require that Board-supervised payment stablecoin issuers fully back their stablecoins with certain permissible reserve assets at all times, according to the Board's September 24, 2026 notice.

The second proposal establishes the supervisory framework and application process for Fed-supervised banks and other entities seeking to issue payment stablecoins. Together, the two packages create the prudential perimeter for stablecoin issuance under Federal Reserve jurisdiction, covering reserve holdings, capital requirements, redemption obligations, risk management, and reporting standards.

The GENIUS Act, signed July 18, 2025, is the first U.S. federal law to regulate stablecoins. It requires issuers to register as Permitted Payment Stablecoin Issuers and establishes a comprehensive federal framework for stablecoin issuance. The statute gave regulators one year to complete implementing rules, a deadline that passed on July 18, 2026 with key federal requirements still unfinished.

All Five Implementing Agencies Missed The July 18 Deadline

All five implementing agencies missed the statutory July 18, 2026 deadline for final rules, according to Clearing Post's August 22, 2026 regulatory desk analysis. No agency has published final rules. The five agencies are the Federal Reserve, the OCC, the FDIC, the National Credit Union Administration, and the Treasury Department.

The missed deadline does not affect the validity of the law itself. The GENIUS Act's effective date remains January 18, 2027, unchanged, according to multiple sources including Cryptonomist's August 18, 2026 report. Stablecoin issuers face a compliance cliff: the law takes effect on that date even if final rules remain unfinished.

Ten Proposals Issued But No Final Rules

U.S. regulators issued ten proposals under the GENIUS Act without finalizing any of them by the statutory deadline, according to Tazapay's August 2026 analysis. The proposals span the Federal Reserve, OCC, FDIC, NCUA, and Treasury, covering licensing, prudential frameworks, reserve requirements, customer identification programs, and state-level oversight.

The OCC proposed implementing regulations on February 25, 2026, adding a new Part 15 to its regulations to establish the supervisory framework for permitted payment stablecoin issuers. The FDIC published its proposed rule on April 10, 2026. Treasury issued its first proposed rule on April 1, 2026, seeking comment on state stablecoin oversight.

Two Stablecoin Proposals Under GENIUS Act Cover Issuer Capital And Redemption Requirements

The Federal Reserve's first proposal requires Fed-supervised payment stablecoin issuers to fully back their tokens at all times with permissible reserve assets. The framework would require Fed-supervised entities to meet requirements for reserve holdings, risk management, redemptions, and reporting, according to Blockchair's coverage of the Fed's September 24, 2026 action.

The second proposal sets capital requirements and a two-day redemption window, along with new reserve disclosures. Under the Fed proposal, issuers would face an operational-risk capital charge equal to 2% of the first $20 billion in stablecoins outstanding, according to KCEX's report on the Fed's GENIUS Act rules.

Capital Requirements Tailored To Business Model And Risk Profile

The GENIUS Act requires that capital requirements be tailored to the business model and risk profile of permitted payment stablecoin issuers, according to Eversheds Sutherland's analysis of the OCC's proposed rulemaking. The Fed's proposal follows the same statutory mandate, applying capital standards calibrated to issuer size and operational complexity.

The OCC's stablecoin proposal provides a detailed prudential framework: issuers with $25 billion or more in outstanding issuance must maintain at least 0.5% of reserve assets, up to a cap of $500 million, according to a LinkedIn analysis of the OCC's March 2026 proposal. The Fed's operational-risk capital charge of 2% on the first $20 billion in stablecoins outstanding represents a parallel approach for Board-supervised issuers.

Reserve Assets And Redemption Mechanics

The Fed's proposal would require that payment stablecoin issuers under its supervision fully back their tokens with certain reserve assets, according to KWSN's September 24, 2026 report. The two-day redemption window means issuers must honor redemption requests within two business days, a requirement designed to ensure stablecoin holders can convert tokens to fiat currency promptly.

The proposal also includes new reserve disclosures, requiring issuers to report the composition and quality of reserve assets backing outstanding stablecoin issuance. The Federal Register's June 12, 2026 publication noted that the proposed rule includes multiple options for reserve asset treatment, reflecting ongoing debate about which assets qualify as permissible reserves under the GENIUS Act.

Which Agencies Missed The GENIUS Act Rule-Making Deadline And What It Means For Stablecoin Issuers

The five implementing agencies that missed the July 18, 2026 deadline are the Federal Reserve, the OCC, the FDIC, the NCUA, and the Treasury Department. Clearing Post confirmed on August 22, 2026 that all five agencies missed the statutory deadline and that no agency has published final rules.

The GENIUS Act mandated that final implementing rules be issued by July 18, 2026, according to KPMG's regulatory alert. The law goes into effect January 18, 2027. With 137 days remaining before the effective date as of early September 2026, regulators only have notices of proposed rulemaking or comment processes in flight, according to CryptoRank's analysis of the compliance cliff.

The Compliance Cliff For Stablecoin Issuers

The GENIUS Act prohibits any person from issuing payment stablecoins unless that person is a permitted payment stablecoin issuer, according to Paul Hastings' crypto policy tracker. The January 18, 2027 effective date creates a hard compliance cliff: entities must be licensed or registered by that date or face a bar on issuing payment stablecoins.

For payroll teams and corporate users, the date that now matters is January 18, 2027, according to Toku's analysis of the missed deadline. The mandatory federal or state licensing takes effect on that date, and entities are barred from issuing payment stablecoins without proper authorization, according to Ebii Insights' LinkedIn analysis.

State-Level Oversight Remains Unresolved

Treasury's April 1, 2026 proposed rule sought public comment on its first proposed regulation implementing the GENIUS Act, focusing on state stablecoin oversight. The proposal outlines when state stablecoin laws can substitute for federal oversight under the GENIUS Act, according to K&L Gates' April 15, 2026 analysis.

The Treasury proposal establishes rules governing who may issue payment stablecoins, with comments due October 19, 2026, according to Sheppard Mullin's blog. The Stablecoin Certification Review Committee, led by the Treasury Secretary, may approve commercial firms that meet various criteria, according to the Congressional Research Service's report on the GENIUS Act.

Public Comment Period On Fed Stablecoin Proposals Runs Until 2026 With Industry Input Expected

The Federal Reserve's two proposals are now open for public comment through the Board's proposals portal. The comment period details are available on the Federal Reserve's website under proposal FR-2026-0005-01, which implements the GENIUS Act's directives to treat permitted payment stablecoin issuers as financial institutions under the Bank Holding Company Act.

The Fed's comment period follows a pattern of extended comment windows across the GENIUS Act rulemaking. Treasury's proposal on payment stablecoin issuance, offer, and sale was published in the Federal Register on August 18, 2026, with comments due October 19, 2026. The customer identification program proposal from multiple agencies had comments due August 21, 2026.

Industry Groups Weigh In On Prudential Frameworks

The American Fintech Council has already responded to the FDIC's stablecoin GENIUS Act implementation proposal, arguing that the FDIC's proposal occupies a determinative position within the broader implementation of the GENIUS Act because it governs the threshold requirements for stablecoin issuers, according to the Fintech Council's advocacy page.

The Conference of State Bank Supervisors submitted comments on August 4, 2026, addressing the FDIC's proposal and its implementation of requirements for stablecoin issuers proposed by FinCEN and the OCC. The CSBS letter, signed by Deputy Executive Secretary Jennifer M. Jones, highlights the coordination challenges across the five implementing agencies.

What To Watch Through Year-End

The base case is that the Federal Reserve's two proposals will attract substantial industry comment through the fall of 2026, with final rules unlikely before the January 18, 2027 effective date. The bull case is that agencies accelerate finalization of the ten outstanding proposals in the fourth quarter of 2026, providing issuers at least some regulatory clarity before the effective date. The bear case is that the compliance cliff arrives with multiple rules still unfinished, forcing issuers to operate under statutory requirements without final implementing regulations.

Three concrete watch items:

  • Fed comment deadline — the Federal Reserve's comment period closing date for the two stablecoin proposals, which will signal the earliest possible finalization timeline for Board-supervised issuers
  • Treasury's October 19, 2026 comment deadline — the closing date for Treasury's proposal on payment stablecoin issuance, offer, and sale, which will indicate whether state-level oversight rules can be finalized before year-end
  • January 18, 2027 effective date — the statutory trigger for mandatory federal or state licensing, which will test whether the ten outstanding proposals can be finalized in time to provide issuers with operational clarity

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