Washington has officially started the countdown to a blockchain revolution. On December 16, the FDIC published a proposed rule under the GENIUS Act, establishing procedures for banks wishing to issue payment stablecoins on public networks. But while regulatory infrastructure will be developed over the next 12–18 months, the first quarter of 2026 will tell a very different story — one about how traditional institutions open the door to millions of retail investors.
Wealth expansion started with Vanguard’s refusal
In early December, an $11 trillion asset company reversed its longstanding ban on cryptocurrencies. Now, 50 million clients worldwide have access to trading third-party Bitcoin and Ethereum ETFs. This doesn’t mean Vanguard is launching its own crypto products — the company has only allowed clients to buy through partner funds.
Meanwhile, Bank of America has shifted its stance. Starting January 5, Merrill and Private Bank advisors can actively recommend Bitcoin ETPs to their clients — not just process client-initiated orders, but suggest allocations of 1% to 4% in major American Bitcoin ETFs. This is a conservative approach, but its scale is impressive: tens of billions of dollars of capital, previously inaccessible, can now be directed into BTC.
Why the first quarter differs from the end of the year
Traditional seasonality in February and March has historically generated returns of 10–15%, and the average first quarter over the past 12 years has shown gains of over 50%. However, 2025 broke this pattern — Q1 ended with a 12% decline, the worst in a decade.
But this year, the situation is clearer. Analysts have already lowered target prices. Standard Chartered revised its end-of-2025 forecast from $200,000 to around $100,000, and for 2026 — from $300,000 to $150,000. This means market positioning has cleared out exaggerated expectations.
The main difference is in the mathematics of distribution, not narratives about halving or regulatory news. When model portfolios from Vanguard and BofA begin adding 1–2% Bitcoin, it’s a measurable flow of capital. The marginal buyer in Q1 2026 will look less like a leveraged hedge fund and more like a pension fund transferring 2% into BTC.
GENIUS Act: infrastructure for 2027, not for January
The FDIC proposal sets clear rules of the game. Payment stablecoins issued by subsidiaries of insured banks must be backed 1:1 with high-quality reserves, with mandatory monthly audits and public disclosures. Rehypothecation is prohibited. This means federal oversight over dollar tokens on the blockchain.
But the live cycle is long. NPRM opens a 60-day comment window. GENIUS becomes effective on January 18, 2027, or 120 days after the final rule is implemented. Even in the most optimistic scenario, the end of 2026 is the earliest realistic timeline for launching the first federally supervised bank stablecoins.
What bank stablecoins will do to the market
When several large banks start issuing dollars on public blockchains under federal oversight, it will transform market infrastructure. Stablecoins could serve as collateral for market makers, settlement assets for prime brokers, and sources of cheap programmable liquidity.
The difference between today’s landscape, dominated by offshore stablecoins, and a world with federally controlled dollar tokens is a shift in trust. Institutional custodians, currently distancing themselves from crypto assets, will be able to store and use such tokens in their operations. This changes not the price of Bitcoin in January, but how blockchain can function as a settlement layer for serious institutional capital in 2027–2028.
Bitcoin’s test in 2026
The first quarter will tell a simpler story than the rest of the year. How many Vanguard clients will press “buy” in February? How many BofA bankrupt clients will accept the 1–2% Bitcoin proposal? Can expanded distribution channels sustain positive seasonality?
At the same time, the countdown for the GENIUS Act continues in parallel. It’s not a candle lighting in January — it’s a nail in the timeline, marking where market infrastructure is headed. If macroeconomic conditions remain stable, federally supervised dollar tokens on the blockchain could become the foundation for large-scale institutional adoption in the next cycle.
For Bitcoin, the next three months will be a test: whether expanded distribution channels and seasonal factors are enough to restore growth after the challenging end of 2025. The answer depends less on headlines and more on flows of real money.
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The countdown has begun: how banks will change the Bitcoin market in 2026
Washington has officially started the countdown to a blockchain revolution. On December 16, the FDIC published a proposed rule under the GENIUS Act, establishing procedures for banks wishing to issue payment stablecoins on public networks. But while regulatory infrastructure will be developed over the next 12–18 months, the first quarter of 2026 will tell a very different story — one about how traditional institutions open the door to millions of retail investors.
Wealth expansion started with Vanguard’s refusal
In early December, an $11 trillion asset company reversed its longstanding ban on cryptocurrencies. Now, 50 million clients worldwide have access to trading third-party Bitcoin and Ethereum ETFs. This doesn’t mean Vanguard is launching its own crypto products — the company has only allowed clients to buy through partner funds.
Meanwhile, Bank of America has shifted its stance. Starting January 5, Merrill and Private Bank advisors can actively recommend Bitcoin ETPs to their clients — not just process client-initiated orders, but suggest allocations of 1% to 4% in major American Bitcoin ETFs. This is a conservative approach, but its scale is impressive: tens of billions of dollars of capital, previously inaccessible, can now be directed into BTC.
Why the first quarter differs from the end of the year
Traditional seasonality in February and March has historically generated returns of 10–15%, and the average first quarter over the past 12 years has shown gains of over 50%. However, 2025 broke this pattern — Q1 ended with a 12% decline, the worst in a decade.
But this year, the situation is clearer. Analysts have already lowered target prices. Standard Chartered revised its end-of-2025 forecast from $200,000 to around $100,000, and for 2026 — from $300,000 to $150,000. This means market positioning has cleared out exaggerated expectations.
The main difference is in the mathematics of distribution, not narratives about halving or regulatory news. When model portfolios from Vanguard and BofA begin adding 1–2% Bitcoin, it’s a measurable flow of capital. The marginal buyer in Q1 2026 will look less like a leveraged hedge fund and more like a pension fund transferring 2% into BTC.
GENIUS Act: infrastructure for 2027, not for January
The FDIC proposal sets clear rules of the game. Payment stablecoins issued by subsidiaries of insured banks must be backed 1:1 with high-quality reserves, with mandatory monthly audits and public disclosures. Rehypothecation is prohibited. This means federal oversight over dollar tokens on the blockchain.
But the live cycle is long. NPRM opens a 60-day comment window. GENIUS becomes effective on January 18, 2027, or 120 days after the final rule is implemented. Even in the most optimistic scenario, the end of 2026 is the earliest realistic timeline for launching the first federally supervised bank stablecoins.
What bank stablecoins will do to the market
When several large banks start issuing dollars on public blockchains under federal oversight, it will transform market infrastructure. Stablecoins could serve as collateral for market makers, settlement assets for prime brokers, and sources of cheap programmable liquidity.
The difference between today’s landscape, dominated by offshore stablecoins, and a world with federally controlled dollar tokens is a shift in trust. Institutional custodians, currently distancing themselves from crypto assets, will be able to store and use such tokens in their operations. This changes not the price of Bitcoin in January, but how blockchain can function as a settlement layer for serious institutional capital in 2027–2028.
Bitcoin’s test in 2026
The first quarter will tell a simpler story than the rest of the year. How many Vanguard clients will press “buy” in February? How many BofA bankrupt clients will accept the 1–2% Bitcoin proposal? Can expanded distribution channels sustain positive seasonality?
At the same time, the countdown for the GENIUS Act continues in parallel. It’s not a candle lighting in January — it’s a nail in the timeline, marking where market infrastructure is headed. If macroeconomic conditions remain stable, federally supervised dollar tokens on the blockchain could become the foundation for large-scale institutional adoption in the next cycle.
For Bitcoin, the next three months will be a test: whether expanded distribution channels and seasonal factors are enough to restore growth after the challenging end of 2025. The answer depends less on headlines and more on flows of real money.