If the 2025 "GENIUS Act" is considered the "Constitutional Moment" for U.S. stablecoins, then the new draft regulation released by the FDIC in April 2026 marks the official beginning of the "Enforcement Era."

This week, the Federal Deposit Insurance Corporation (FDIC) published a proposed rule in the Federal Register, opening a comment period of nearly two months, ending on June 9. It provides clear constraints and guidelines regarding the issuance of stablecoins by banks and fintech subsidiaries.
In simple terms, the FDIC is turning the 2025 enacted "Guidelines and Establishment of a U.S. Stablecoin Innovation Act" (GENIUS Act) into more concrete and enforceable operational checklists and regulatory rules.
Why does the FDIC have the authority to speak? The legitimacy of regulatory power.
To understand the significance of this draft, one must first understand the background of the FDIC.
The FDIC, officially the Federal Deposit Insurance Corporation, is an independent federal agency established by Congress. Its core responsibilities include insuring bank deposits, examining and supervising the safety and soundness of financial institutions, and handling bank failures.
The FDIC directly supervises a large category of state-chartered banks and savings institutions that are not members of the Federal Reserve System, giving it the authority to set rules on their safety, capital, liquidity, customer protection, and deposit insurance coverage. In domestic terms, this is similar to the functions of the China Banking and Insurance Regulatory Commission (CBIRC).
Therefore, the FDIC inherently has regulatory authority to issue draft guidelines on stablecoins. If a bank or its subsidiary issues new liabilities related to the U.S. dollar payment system, the FDIC would naturally be concerned with risks related to capital, liquidity, redemption, custody, disclosure, and misleading sales.
The draft guidelines released this time mainly target stablecoin issuers within the FDIC-regulated banking system, especially "Qualified Payment Stablecoin Issuers" (PPSI) established by FDIC-regulated depository institutions through subsidiaries, and also cover some custody and safekeeping activities.
More importantly, this is directly authorized by the "GENIUS Act." The law was signed by Trump on July 18, 2025, explicitly requiring the FDIC, OCC, Federal Reserve, NCUA, and the Treasury Department to develop implementation rules for stablecoin issuers within their respective jurisdictions.
For the FDIC, it is the primary regulator of stablecoin subsidiaries operated by state non-member banks and state savings institutions under its supervision.
This also explains its relationship with existing stablecoin legislation: this draft is not new legislation but one of the implementation rules of the GENIUS Act. The GENIUS Act is already the first comprehensive federal legal framework for stablecoins in the U.S., requiring only "licensed payment stablecoin issuers" to legally issue such stablecoins in the U.S., with bank subsidiaries regulated by their main banking supervisor, and federally licensed non-bank issuers primarily overseen by the OCC.
In December 2025, the FDIC had already issued a preliminary draft on "how bank subsidiaries can apply for approval to issue stablecoins." The April 2026 draft further adds substantive requirements for reserves, redemption, capital, liquidity, risk management, custody, and disclosure after approval.
It sends a clear signal to the banking industry: do not try to exploit the line between deposit insurance and tokenized deposits.
Six key points of the new regulation: from "1:1 reserves" to "prohibition of interest payments."
Looking specifically at this FDIC draft, the most important parts define six rules for the stablecoin game within the banking system.
First is reserve assets. The draft requires issuers to always maintain at least a 1:1 ratio of identifiable reserves to cover all circulating stablecoins, and the value of these reserves must never fall below the total face value of unredeemed stablecoins at any point. Issuers must also keep records linking specific reserves to particular stablecoin brands.
The FDIC also proposes that if a subsidiary issues multiple different stablecoin brands, each brand should have a segregated, traceable, and separately recorded reserve pool, avoiding mixing to reduce the risk of contagion if one fails.
Second is the quality, liquidity, and realizability of reserves. The draft not only requires issuers to hold at least a 1:1 ratio of identifiable reserves but also emphasizes that these reserves must have strong liquidity to be quickly converted into usable funds during redemption pressure.
Regarding the use of reserve assets, the FDIC plans to explicitly restrict arrangements such as rehypothecation or reuse of reserves.
For repurchase agreements based on short-term U.S. Treasury securities, the draft proposes a conditional framework. For reverse repos, it is still seeking opinions on how to define excess collateral and whether more specific restrictions are needed, with no fully clear limits yet.
Third is the "T+2" redemption deadline. The FDIC requires issuers to publicly disclose redemption policies, including timing, procedures, and minimum redemption amounts.
"Timely redemption" is defined as completing within two business days after a redemption request.
Any discretionary restrictions on timely redemption should generally be approved by the FDIC, not decided solely by the issuer. The minimum redemption amount cannot exceed one stablecoin, ensuring retail investors' rights.
Fourth is a "positive and negative activity list." The FDIC limits the "core activities" of payment stablecoin issuers to issuance, redemption, reserve management, and limited custody services. Other activities can only directly support these core functions, with "direct support" subject to regulatory interpretation.
The draft also explicitly states several restrictions:
- Cannot imply that stablecoins are backed by U.S. government credit.
- Cannot imply federal deposit insurance coverage.
- Cannot pay interest or yields solely because users hold or use stablecoins.
- Issuers are prohibited from lending to customers to buy their own stablecoins, as this would introduce leverage into the "1:1 reserve" backing.
Fifth is the management of capital, liquidity, and risk resilience. The FDIC does not simply adopt standard banking capital ratios but proposes a more flexible framework.
PPSI must hold at least CET1 and AT1 capital instruments as regulatory capital and establish self-assessment and compliance processes.
For more complex or higher-risk activities, the FDIC can require additional capital or reserve buffers.
The FDIC believes that if an issuer only conducts narrow issuance and redemption activities, capital requirements may be lower. But engaging in more activities increases the importance of capital adequacy.
Sixth is the weekly and monthly disclosure system. The draft requires issuers to disclose reserve composition monthly on their websites, along with redemption policies and related fees.
Issuers must also submit confidential weekly reports to the FDIC.
More importantly, the monthly reserve disclosures are not solely by the issuer; the draft requires an independent CPA to review and issue a written report on the monthly data.
Additionally, the CEO and CFO must certify the accuracy of the monthly reports to the FDIC.
By linking public disclosure, third-party review, and executive accountability, the draft significantly raises the bar for ongoing compliance and information authenticity.
A more sensitive point is that the FDIC clarifies that deposits held at banks as stablecoin reserves should not be claimed as FDIC insurance through "piercing the corporate veil."
It also clarifies that if a "tokenized deposit" essentially qualifies as a deposit, it will not be treated differently just because it is on-chain or tokenized under the Federal Deposit Insurance Act.
In other words, stablecoins are not deposit insurance products, but genuine "tokenized deposits" may still be considered deposits and be insured.
How will the "new regulation" influence the market?
Currently, this draft is only a proposed rule, not a final regulation, and it applies only to FDIC-regulated banks/subsidiaries and related custody activities.
The FDIC estimates that in the initial years, only about 5 to 30 FDIC-regulated institutions might apply for and obtain approval to issue stablecoins through subsidiaries, with dozens more providing custody services.
However, the regulatory impact is significant. First, it is the real implementation of the GENIUS Act, transforming abstract legislation into enforceable regulation.
Together with the OCC's parallel rules issued in February and the Treasury's AML/sanctions rules in April, it is shaping a comprehensive federal stablecoin regulatory framework.
Finally, it will significantly influence future market competition: institutions with stronger compliance capabilities, capital, and banking infrastructure will have advantages over "light-asset, marketing, and yield-driven" crypto-native models.
Especially, the restrictions on paying interest to holders, limits on reserve reuse, and strict statements on FDIC insurance could favor traditional banks and highly compliant issuers.
Therefore, this draft should not be seen as a broad positive for crypto but as a crucial step in refining U.S. stablecoin regulation into concrete regulatory text.
Legislatively, it is subordinate to the GENIUS Act, but practically, it is far more important than political slogans.
Traditional banking giants with licenses, strong capital, and the capacity to endure strict audits and low margins will soon have their own compliant stablecoin playground.
The U.S. stablecoin landscape is about to usher in a new wave.