Fed Proposes GENIUS Act Rules for Payment Stablecoin Issuers

According to an Orrick alert, the Federal Reserve requested public comment on September 24 on two proposed rules implementing the GENIUS Act, enacted in July 2025 to create a regulatory framework for payment stablecoins. The first proposal would establish reserve, capital and related requirements for issuers; the excerpt available here does not describe the second proposal's subject matter, so its scope should be confirmed against the full text.

Why sophisticated counsel should care: GENIUS Act implementation is moving from statute into supervised rulemaking, and the reserve and capital framework determines what backs stablecoin par, how issuer balance sheets compare with bank deposits and money market funds, and what supervisory perimeter issuers and their sponsors now operate inside. The same rulemaking touches banking, payments and corporate treasury teams at once — issuer sponsors, banks pursuing issuance or custody relationships, and clients with stablecoin settlement or cross-border payments mandates.

What to watch: the operative dates are the comment deadlines, which are not stated in the available material, plus any proposed-to-final revisions to reserve and capital tiers. Firms and clients will need the Federal Register text to map requirements onto existing issuance, custody and distribution arrangements. This is a notice of proposed rulemaking, not final rules, and the alert is a single-source summary of the Fed action.