In the span of one week, the U.S. regulatory framework for stablecoins moved from an abstraction to an operational reality.

On April 1, 2026, the U.S. Treasury issued its first notice of proposed rulemaking under the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act. Six days later, on April 7, the Federal Deposit Insurance Corporation (FDIC) followed with its own proposed rule, outlining the prudential standards that bank-supervised stablecoin issuers will be required to meet.

These are not the same rule. Together, they form the two-layer architecture that will govern stablecoins in the United States by January 2027.

Understanding both matters for anyone building, investing in, or advising stablecoin infrastructure.

What the Treasury Rule Does

The Treasury’s 87-page proposal addresses a specific threshold in the GENIUS Act: stablecoin issuers with less than $10 billion in outstanding supply can operate under state-level regulation, provided that state framework meets or exceeds federal standards.

What Treasury proposed are the benchmark principles states must match. The rule distinguishes between two categories of requirements.

The first category, “uniform requirements,” cannot be weakened at the state level. These include reserve backing and anti-money laundering compliance. The second category, “state-calibrated requirements,” gives local regulators discretion in areas such as capital standards and risk management, within limits.

The rule anchors its federal benchmark largely to standards issued by the Office of the Comptroller of the Currency. That signals which agency will carry the most weight in overseeing nonbank stablecoin issuers that scale past the $10 billion threshold and graduate to federal supervision.

For smaller issuers, the practical effect is that the regulatory environment will vary by state. The rule requires monthly reserve composition disclosures and imposes naming restrictions that apply to both state and federally regulated issuers.

What the FDIC Rule Does

The FDIC’s proposed rule goes deeper into operational requirements. It applies specifically to “permitted payment stablecoin issuers,” or PPSIs, which are subsidiaries of FDIC-supervised banks and savings associations.

The core requirements are:

• Reserves: Full 1:1 backing at all times. Eligible assets are narrowly defined: U.S. currency, Federal Reserve balances, short-term Treasury securities (93-day maximum maturity), overnight repos, and government money market funds. No pledging or rehypothecation of reserves except in narrow circumstances.
• Capital: New PPSIs must hold a minimum of $5 million in capital for their first three years of operation. Ongoing capital must consist primarily of common equity tier 1 and additional tier 1 instruments. Higher-risk activities attract additional capital expectations.
• Liquidity: Issuers must maintain a separate liquidity buffer covering 12 months of operating expenses, and must monitor reserve compliance in real time throughout the business day.
• Redemption: Standard redemptions must be processed within two business days. If withdrawals exceed 10% of outstanding issuance within a 24-hour window, the issuer must notify the FDIC and may request an extension.
• Prohibited activities: Paying yield or interest to stablecoin holders is explicitly prohibited. So is marketing stablecoins as FDIC-insured. Lending to customers to purchase stablecoins is also prohibited.

The FDIC rule is open to a 60-day public comment period. Final rules are expected in the third or fourth quarter of 2026.

The Structure That Is Emerging

Reading both rules together, a clear architecture emerges.

The Treasury rule governs who can participate and at what scale, and sets the floor for state-level frameworks. The FDIC rule governs how bank-subsidiary stablecoin issuers must operate day-to-day.

For issuers below $10 billion, regulatory treatment will depend heavily on which state they operate in and whether that state’s framework is deemed substantially similar to the federal standard. For issuers above $10 billion, or those choosing federal oversight directly, the OCC and FDIC become the primary regulators.

The architecture is designed to preserve state flexibility while preventing a race to the bottom. States can exceed federal standards. They cannot fall below them.

What This Means in Practice

Several implications stand out for operators and investors in the stablecoin space.

Compliance posture is now a structural advantage. Issuers who build to the federal standard from the outset will not need to retrofit their operations when final rules take effect. Those who delay will face both the cost of retrofitting and the reputational risk of being seen as behind the regulatory curve.

The yield prohibition changes the product design landscape. Payment stablecoins regulated under this framework cannot pay yield to holders. Products that generate yield on stablecoin-adjacent instruments will need to be structured carefully to avoid classification as payment stablecoins subject to these rules.

The $10 billion threshold creates a two-speed market. Smaller issuers operating under state frameworks will have more flexibility in the near term. As the market matures and assets under management grow, the federal standard effectively becomes universal.

Banking relationships become gating infrastructure. PPSIs must be subsidiaries of FDIC-supervised institutions. This means access to the US market for stablecoin issuance now requires a banking relationship at the structural level, not just operationally.

The Timeline

The GENIUS Act was enacted in July 2025. It becomes effective January 18, 2027, or 120 days after final rules are issued, whichever comes first.

With the FDIC’s 60-day comment period running through approximately mid-June, final rules are realistically expected between August and October 2026. Operators who want to be compliant at launch have approximately six months to prepare.

The comment period also represents an active window for institutional stakeholders to shape how the final rules are written. The FDIC is accepting public comments at comments@fdic.gov, identified by RIN 3064-AG19.

Sora Ventures’ Perspective

At Sora Ventures, we have tracked the GENIUS Act closely since passage because the stablecoin infrastructure it creates is directly relevant to the markets where we operate. Our portfolio companies and partners are building across Hong Kong, Japan, Korea, Thailand, Vietnam, and Taiwan, and the US framework sets a benchmark that other jurisdictions are watching closely.

Hong Kong’s own stablecoin licensing regime under the HKMA missed its March 2026 target date. The US moving systematically toward a functional framework while Asia regulators lag is a dynamic that shapes where institutional capital flows and which operators are positioned to move when regulatory clarity arrives.

The direction is clear but the specifics are still being written. Now is the time to be in the room.