Share on LinkedInShare on LinkedIn

ARTICLE · 24 DECEMBER 2025

FDIC Proposes Application Framework For Bank-Affiliated Payment Stablecoin Issuers

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
Contributor
Hogan Lovells Cadwalader

Hogan Lovells Cadwalader

Hogan Lovells Cadwalader is a global law firm trusted by clients to deliver on complex, high-stakes...

View firm profile
Explore more from Hogan Lovells Cadwalader

On December 16, 2025, the FDIC issued a notice of proposed rulemaking to implement the application and approval requirements under the Guiding and Establishing National Innovation...

United StatesFinance and Banking

On December 16, 2025, the FDIC issued a notice of proposed rulemaking to implement the application and approval requirements under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”) for insured state nonmember banks and state savings associations seeking to issue payment stablecoins through a subsidiary. The proposal would add a new § 303.252 to the FDIC's filing procedures in 12 C.F.R. Part 303, establishing a tailored, statute-driven process for obtaining FDIC approval to form and operate a “permitted payment stablecoin issuer” (“PPSI”) subsidiary.

Consistent with the GENIUS Act, the proposed rule emphasizes safety and soundness as the sole basis for approval or denial. Applications would be evaluated against the statutory factors set forth in section 5(c) of the Act, including the subsidiary's financial condition and resources, its ability to meet reserve, redemption, and disclosure requirements, the competence

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

See more popular content from