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ARTICLE · 09 APRIL 2026

FDIC Proposes GENIUS Act Rules: How Do They Compare To The OCC Proposal?

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The FDIC has issued a comprehensive proposal to implement the GENIUS Act for payment stablecoin issuance by entities under its jurisdiction, introducing notable differences from the OCC's earlier framework.

United StatesFinance and Banking
Matthew Bisanz
Matthew Bisanz
Andrew Olmem
Andrew Olmem
Anna T. Pinedo
Anna T. Pinedo
Joseph A. Castelluccio
Joseph A. Castelluccio
Jeffrey P. Taft
Jeffrey P. Taft
Don F. Irwin
Don F. Irwin
Kelly F. Truesdale
Kelly F. Truesdale
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On April 9, 2026, the Federal Deposit Insurance Corporation (“FDIC”) issued a Notice of Proposed Rulemaking (the “FDIC Proposal”) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”) for the issuance of payment stablecoins and certain related activities by entities subject to the FDIC’s jurisdiction.

The FDIC Proposal generally tracks a similar proposal that the Office of the Comptroller of the Currency (“OCC”) issued earlier this year for entities subject to OCC regulation (the “OCC Proposal”), with certain notable deviations. Additionally, the FDIC Proposal addresses the eligibility of stablecoin reserves for pass-through deposit insurance and tokenized deposits for deposit insurance.

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