What happened?
Circle filed a comment letter with the U.S. Treasury on implementing the GENIUS Act and laid out a proposed national framework for payment stablecoins. It recommends rules requiring full backing with cash and high-quality liquid assets, segregation of reserves, redemption at par, independent monthly checks, clear disclosures, and a standalone issuer structure. The letter pushes “same activity, same rules,” asks for reciprocal paths for qualifying foreign issuers, and seeks published determinations, safe harbors, predictable penalties, and tested wind-down plans.
Who does this affect?
This affects payment stablecoin issuers — both banks and nonbanks — plus foreign issuers that want U.S. access, and intermediaries like exchanges, banks, brokers, and payment platforms. It matters to corporate treasurers, auditors and accounting teams because Circle asks that permitted stablecoins be treated as cash and cash equivalents and wants clarity on liquidity management and interoperability. Regulators and supervisors are also impacted since the proposal calls for ongoing oversight, published determinations, independent verification, and clear enforcement and compliance protections.
Why does this matter?
Clear, uniform rules and a fully reserved model would increase trust in stablecoins and make them more practical for real-world and cross-border payments, which could drive broader adoption. That should reduce fragmentation between banks, brokers and exchanges, align accounting and tax treatment so businesses can use tokens like cash, and improve predictable liquidity and settlement across time zones. At the same time, stronger prudential requirements and supervision could raise compliance costs and favor well-capitalized firms, reshaping competition while enhancing consumer protection and market stability.
