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ARTICLE · 11 NOVEMBER 2026

Arnold & Porter Discusses Implementing The GENIUS Act

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The Federal Reserve Board has issued two companion notices of proposed rulemaking to implement its responsibilities under the GENIUS Act, establishing comprehensive procedures for insured state...

United StatesFinance and Banking
Eun Young Choi
Eun Young Choi
David Freeman, Jr.
David Freeman, Jr.
Amber A. Hay
Amber A. Hay
Anthony Raglani
Anthony Raglani
Kevin Toomey
Kevin Toomey
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On September 24, 2026, the Board of Governors of the Federal Reserve System (Board) issued two companion notices of proposed rulemaking to implement its responsibilities under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act or Act).1 One proposal would establish the procedures an insured state member bank must follow to obtain Board approval for a subsidiary to become a Board-supervised permitted payment stablecoin issuer (PPSI) (the Application Proposal).2 The other would implement substantive reserves, capital, redemption, risk management, custody, and reporting requirements for PPSIs; establish safeguards for Board-supervised custodians; and clarify certain stablecoin activities of Board-regulated firms (the Framework Proposal) (together, the Proposals).3

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