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ARTICLE · 26 DECEMBER 2025

FDIC Proposes Application Procedures For Supervised Entities To Issue Stablecoins Through A Subsidiary

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On December 16, 2025, the Federal Deposit Insurance Corporation (FDIC) Board of Directors approved a notice of proposed rulemaking...

United StatesFinance and Banking
Alan Cohn
Alan Cohn
Alexandra C. Scheibe
Alexandra C. Scheibe
Benjamin Saul
Benjamin Saul
Evan T. Abrams
Evan T. Abrams
Juliana Gerrick
Juliana Gerrick
Neel K. Chopra
Neel K. Chopra

On December 16, 2025, the Federal Deposit Insurance Corporation (FDIC) Board of Directors approved a notice of proposed rulemaking (NPRM or Proposed Rule) implementing provisions of the Guiding and Establishing National Innovation for US Stablecoins Act (GENIUS Act), allowing insured depository institutions (IDIs) to issue payment stablecoins through a subsidiary.1The NPRM establishes application procedures for an FDIC-supervised IDI to apply for and obtain FDIC approval "to issue payment stablecoins through a subsidiary."2

GENIUS Act Background

President Trump signed the GENIUS Act to law on July 18, 2025. Section 3(a) of the GENIUS Act limits the issuance of payment stablecoins in the US to permitted payment stablecoin issuers (PPSIs).3There are three pathways for an entity to become a PPSI under the GENIUS Act, the NPRM concerns only one: "a subsidiary of an [IDI] that has been approved to issue payment stablecoins" pursuant to section 5 of the Act.4The

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