Treasury Issues Interim Final Rule for State Stablecoin Certification Review
Treasury, for the Stablecoin Certification Review Committee, issued an interim final rule on September 30 setting interim procedures and forms for reviewing state stablecoin certifications under Section 4(c) of the GENIUS Act.
What happened: On September 30, the U.S. Treasury Department, on behalf of the Stablecoin Certification Review Committee, issued an interim final rule establishing interim procedural regulations and forms governing the Committee's review of state certifications submitted under Section 4(c) of the GENIUS Act. The rule is procedural rather than substantive — it sets out how certification applications move through review and what filings must look like — but it is the first operative framework for the federal-state division of authority over stablecoin issuer approval.
Why sophisticated counsel should care: the GENIUS framework expressly contemplates state-level certification pathways, and the mechanics of that review determine whether a client structures as a state-chartered issuer pursuing certification, waits for federal implementation, or pursues a parallel strategy. Filing requirements and review timing will shape the schedule for capital, reserve, disclosure, and redemption-compliance build-outs, and will bear on offering and disclosure documents that reference an issuer's regulatory status.
What to watch next: the comment and response cycle for this interim final rule, any conforming Committee guidance or forms, and how states align their own certification regimes with the federal procedures. This summary rests on a single secondary report, so the operative text should be read directly before advising clients.