Washington decided that stablecoins were too important, both economically and systemically, to remain outside regulatory scope. Now comes setting the rules.
With the one-year anniversary of the GENIUS Act being signed into law this July, the United States is in full implementation mode. The clock is running.
Federal Deposit Insurance Corporation (FDIC)Federal Deposit Insurance Corporation (FDIC).) Proposed rule It directly links the issuance of stablecoins to reserve integrity, liquidity discipline, and custodial supervision. Comments will close early next month.
the Office of the Comptroller of the Currency (OCC), meanwhile, is doing a full buildout Prudential framework For stablecoin issuers.
Read together, the two frameworks reveal an emerging division of organizational labor. The OCC positions itself as the primary prudential supervisor for stablecoin issuers, especially federally chartered entities. The Federal Deposit Insurance Corporation (FDIC) is staking its claim as the guardian of the integrity of deposit insurance and the stability of bank balance sheets as token financing expands.
See also: Stablecoin pilots continue to stall on their path to expansion
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OCC’s expanded vision for the digital dollar
Washington wants stablecoins to become legitimate financial infrastructure. But it also wants infrastructure to be much more like banking than Silicon Valley. the PYMNTS INTELLIGENCE and City a report “Chain Reaction: Regulatory Clarity as a Catalyst for Blockchain Adoption“I found that the next leap for blockchain will be shaped by regulation.
The GENIUS Act leaves unresolved a critical enforcement challenge: How aggressively should agencies supervise issuers that are not traditional banks? This question is at the heart of both the FDIC and OCC’s proposals.
The OCC moved first and proposed a more comprehensive framework. Its rules apply not only to bank affiliates but also to federally qualified non-bank stablecoin issuers, putting the agency at the center of a potential new supervisory regime.
The system has already begun to expand at the edges. PYMNTS has Covered how A Trust Charter From OCC it became equivalent to a Golden ticket Across the digital assets space. On Friday (May 8), Payward, the parent company of cryptocurrency exchange Kraken, Applied To seek a national trust bank charter to form Payward National Trust Company, a federally regulated entity intended to provide digital asset custody services to institutional investors. The move would expand Kraken’s reach in the United States Organizational footprint Following the 2020 approval of Kraken Financial’s Wyoming Special Purpose Depository Institution and Charter Arriving later this year To a Federal Reserve master account, enhancing the company’s regulated custody operations.
But the OCC’s proposal sounds less like a cryptocurrency policy document and more like a modern banking guide. It sets standards for reserves, liquidity, redemption rights, audits, governance, reporting obligations and operational flexibility. The proposal would also require weekly confidential reporting on issuance activity, reserve composition, trading behavior and recovery metrics.
See also: The shadow market for foreign stable currencies has become an issuance for corporate treasuries
The FDIC’s more targeted approach.
The FDIC’s proposal overlaps significantly with the OCC’s framework but takes a narrower institutional view. Rather than creating a broad supervisory structure for all stablecoin issuers, the FDIC is focusing primarily on FDIC-supervised institutions and custody arrangements.
For example, growing corporate interest in stablecoins is seen in… “Stablecoins Gain: Why CFOs See More Promise from Cryptocurrencies” PYMNTS Intelligence’s March Data Book tracks how mid-market finance leaders value digital assets.
In particular, the Federal Deposit Insurance Corporation (FDIC) has clarified that reserves backing payment stablecoins will not receive pass-through deposit insurance protection for stablecoin holders. Regulators are trying to encourage adoption while at the same time preventing users from confusing stablecoins with secured cash accounts. In practical terms, this means that users who own stablecoins should not afford the same protections they receive with traditional bank deposits.
The FDIC proposal also addresses token deposits, suggesting that if token liabilities meet the legal definition of a deposit, they should receive equivalent treatment under existing banking law. This requirement may ultimately prove more transformative than the stablecoin rules themselves. Large financial institutions are increasingly looking to token deposits, not privately issued stablecoins, as a long-term bridge between traditional banking and blockchain-based finance. The FDIC may actually be preparing for a future in which regulated banks issue programmable deposits directly on digital ledgers.
See also: The Treasury Department calls for programmable financial enforcement via cryptocurrencies
The future of digital dollars
Agencies also differ in their treatment of innovation pathways. The OCC has proven more willing to accommodate federally chartered non-bank stablecoin issuers under a dedicated supervisory structure. This creates a path for domestic fintech companies to operate nationally under federal oversight. The FDIC is relatively cautious and directs its activity more directly through traditional insured depository institutions.
Another important difference is how regulators think about transferring risk. The OCC proposal places greater emphasis on liquidity risk and real-time redemptions, requiring accurate reporting on reserve composition, issuance activity, and redemption behavior. This reflects concern that stablecoins can quickly transmit stress through treasury markets or payment systems during periods of market instability.
At the same time, the FDIC focuses more on legal and institutional boundaries. Its proposal devotes significant attention to whether tokenized liabilities qualify as deposits under current banking law and how insured banks should hold or manage stablecoin reserves. In other words, the FDIC primarily protects the banking perimeter, while the OCC oversees the stablecoin ecosystem itself.
Perhaps the deepest competition is no longer about which stablecoin will win market share. Instead, the real competition could revolve around who controls the infrastructure surrounding stablecoins: custody, settlement, reserve management, payments connectivity, and access to Federal Reserve systems.
