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ARTICLE · 29 DECEMBER 2025

FDIC Proposes GENIUS Act Application Process For IDI Subsidiary Stablecoin Issuers

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On December 16, 2025, the Federal Deposit Insurance Corporation ("FDIC") Board of Directors issued a proposal (the "NPRM") to implement the application-related provisions...

United StatesFinance and Banking
Matthew Bisanz
Matthew Bisanz
Joseph A. Castelluccio
Joseph A. Castelluccio
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Andrew Olmem
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Don F. Irwin
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Kelly F. Truesdale
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On December 16, 2025, the Federal Deposit Insurance Corporation (“FDIC”) Board of Directors issued a proposal (the “NPRM”) to implement the application-related provisions of the Guiding and Establishing National Innovation for US Stablecoins Act (the “GENIUS Act”) for subsidiaries of FDIC-supervised insured depository institutions (“IDIs”).

The FDIC's proposed application process closely tracks the GENIUS Act's statutory factors, timelines, and denial standard while building out the application process, content and requirements in a manner that is consistent with existing FDIC processes applicable to FDIC-supervised IDIs. Comments are due no later than February 17, 2026.

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