The U.S. Department of the Treasury has taken an important step in the practical implementation of the GENIUS Act by publishing a draft of regulatory requirements for issuers of payment stablecoins. This document, known as the Notice of Proposed Rulemaking (NPRM), is designed to translate legislative principles into specific operational rules for participants in the digital dollar market.
Key Aspects of the New Regulation
The proposed draft focuses on Section 3 of the GENIUS Act, defining criteria for classifying payment stablecoins, the procedures for their issuance and offering, as well as mechanisms for jurisdictional oversight. In essence, the regulator is establishing which companies will be able to legally operate with these assets under the new federal regime formally codified into law in July 2025.
Particular attention in the document is paid to reserve requirements. Issuers are obligated to back stablecoins with assets on a 1:1 basis, with the list of permissible reserves strictly limited to highly liquid instruments: U.S. dollars, bank deposits, and short-term Treasury securities. Mandatory periodic disclosures about reserve composition and independent audits of such data are also provided. This is a critically important mechanism designed to guarantee holders the ability to redeem tokens at par value and minimize systemic risks to financial stability.
It is important to emphasize that the introduction of strict standards does not imply the creation of government insurance protection for stablecoin holders. Previously, the head of the FDIC separately noted that holders of such assets would not receive guarantees similar to bank deposit insurance.
Next Steps and Context
At this point, the published NPRM is only a draft. The Treasury has opened a public comment period during which market participants can submit their remarks and suggestions. This is already the second stage of rulemaking under the GENIUS Act — in April, the agency presented rules concerning the coordination of the federal regime with state-level regulation.
It is worth recalling that the statutory deadline for developing these regulatory frameworks expired back on July 18, indicating a certain delay in the process. However, after the final rules are published, the full regulatory regime must take effect within 120 days. In parallel, the Senate continues to consider the CLARITY Act bill, which could introduce additional adjustments to stablecoin regulation, particularly in the area of banking activities.
My commentary: The Treasury's initiative is long-awaited specificity that is finally beginning to turn the GENIUS Act from a political declaration into a working mechanism. However, the key question remains not so much the content of the rules as the speed of their finalization. Given the missed deadline and ongoing debates in Congress, the market should prepare for the fact that full clarity on this matter will not emerge before the end of the year.