The Federal Reserve’s regulatory service page lists the item in the usual calm hand. The Board proposes regulations to implement the GENIUS Act for stablecoin issuers, and comments are due November 30.
What the listing leaves out is the calendar. The statute gave regulators until July 18, 2026 to finish the job. The Board’s proposals were released on September 24, and they are still proposals.
A Deadline Everyone Missed Together
The GENIUS Act became law on July 18, 2025. It sets up a federal framework for stablecoins used as payment and bars anyone but a permitted issuer from issuing one in the United States. The details of reserves, capital and risk management were left to the regulators, who were told to issue implementing regulations within one year.
They did not. The Block reported that Treasury and the four primary regulators reached the deadline without a final set of rules. The law does not say a missed deadline extends or suspends anything, so the effective date stayed where it was.
The Fed was not alone. It was, however, the only one of the banking regulators whose own substantive proposal was still unpublished when the date passed.
The Board’s own Federal Register notice makes the comparison easy. It cites ten earlier GENIUS Act proposals across the government, starting with the FDIC’s in December 2025 and ending with Treasury’s in August.
The Board appears in exactly one of them. That is a joint proposal from June, which Forkast described as the Fed’s only public contribution before the deadline. It is a customer identification rule shared with four other agencies.
Seven Months Behind the Comptroller
The OCC’s proposal ran in the Federal Register on March 2, 2026. The Board’s ran on September 29, about seven months later.
Regulators are supposed to coordinate, and the Board’s notice leans into it. It says many aspects of its proposal are similar to the notices from the OCC, FDIC and NCUA. It tags its own questions with the numbers of the matching OCC questions.
On the ban on paying yield to stablecoin holders, the notice says the Board is proposing to follow the OCC’s approach.
None of that is improper. Borrowing a working template is how agencies avoid writing the same rule five different ways.
It does raise the obvious question. If the Board’s text tracks a proposal that had been public since March, what took until late September?
That is an inference, not a finding. It rests on the Board’s own wording about the similarity to the OCC’s notice, and on the seven-month gap between the two publication dates. The notice itself offers no explanation for the timing.
To be fair, the proposal is not a photocopy. It adds a custody subpart, rules for state-qualified issuers, and a tying prohibition that applies to every permitted issuer, whoever supervises it.
Forty-Five Questions Before the Reserves
The notice runs more than 100 pages in the Federal Register. By the time it reaches reserve assets, it has already posed 45 numbered questions about definitions and permitted activities.
The substance is what the statute requires, plus the Board’s judgment calls. Reserves must back outstanding stablecoins at least one to one. Issuers could not lend.
Paying yield to holders is barred. The Board would presume that certain arrangements with affiliates or related third parties amount to paying it, unless the issuer rebuts the presumption in writing to the Board’s satisfaction.
The Board also asks commenters what effect the yield prohibition would have on bank deposits. That is Question 40 in the notice. The notice does not say what the Board expects the answer to be, and it does not say how much of the rule’s design depends on it.
Then come the open questions. The Board asks whether it should limit each issuer to a single brand of stablecoin. It also floats requiring the reserves behind each brand to sit in a separate subsidiary with no liabilities of its own.
The notice adds that the Board expects to update these regulations in the years ahead as issuers’ business practices change. American Banker’s coverage reports that Governor Michael Barr said further work will be needed if stablecoins are to become reliable payment instruments.
Open questions are the point of a proposal. The timing is the problem. They are being asked after the date by which the answers were due.
Seven Weeks to the Cliff
The Act takes effect on the earlier of two dates. One is 18 months after enactment, which is January 18, 2027. The other is 120 days after the primary regulators issue final rules. The Board’s notice says as much.
Comments close November 30. That leaves 49 days before the January date. A companion proposal on applications from state member banks, Docket R-1900, carries the same comment deadline.
The arithmetic on the early option closed some time ago. As The Block noted, any final rule issued after September 20 cannot pull the date earlier than January 18, because 120 days from then lands on that date. The Board’s proposals were released four days after that point.
The OCC appears to be on a different track. PYMNTS reported that Comptroller Jonathan Gould said in August that the OCC expects to have a final rule out by November.
If both timelines hold, issuers under the OCC could face January with a final rule in hand. Issuers under the Board could face it with a final rule still to be written.
That, too, is an inference. It rests on Gould’s stated timeline, the Board’s November 30 comment deadline, and the fact that the Board must work through the comments before it can finalize anything. The Board has not said when it expects to finish.
Inquiries are being directed to the Federal Reserve Board. Three questions stand out:
- Why did the Board’s proposal follow the OCC’s by about seven months and arrive after the statutory deadline?
- Does the Board expect to issue final rules before January 18, 2027?
- If not, what will govern Board-supervised issuers and applicants when the Act takes effect?
The regulatory service page tells readers when to send their comments. It is silent on what the final rule will say, or whether there will be one, when the statute arrives on January 18.
