The American Bankers Association (ABA) has urged the Federal Deposit Insurance Corporation (FDIC) to align its stablecoin rulemaking with that of the Office of the Comptroller of the Currency (OCC) and the other primary regulators implementing the GENIUS Act.
It exposed a potential ambiguity around when the GENIUS Act comes into effect. The date is the earlier of 18 months after enactment (January 18, 2027) or 120 days after the primary Federal payment stablecoin regulators issue final regulations. Depending on the interpretation, that could mean the law becomes effective once a single regulator finalizes its rules.
Turning to the rules themselves, the association highlighted a difference in the FDIC rulemaking that could reduce customer protections. The FDIC defines stablecoin customers as only those who acquire stablecoins directly from the issuer, usually a minority and a group dominated by intermediaries. The OCC’s definition is broader. The ABA also notes that the GENIUS Act does not legally distinguish between a customer and a holder.
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