One year after President Trump signed the GENIUS Act into law on July 18, 2025, the statute's own implementation clock has run out. Congress gave federal regulators exactly twelve months to translate the first US stablecoin law into binding rules, and that July 18, 2026 rulemaking deadline has now arrived with six agencies having pushed out proposals covering everything from reserve audits to sanctions screening. The stakes are considerable: dollar-pegged tokens now account for roughly $263 billion in circulation, and America's largest banks have spent the past year positioning themselves to compete for that money.
What the GENIUS Act rulebook actually says
The rulemaking sprint that led up to the deadline was unusually broad. According to the ABA Banking Journal, the Office of the Comptroller of the Currency issued a 350-plus-page notice of proposed rulemaking on February 25, 2026, establishing uniform standards for what the law calls Permitted Payment Stablecoin Issuers, or PPSIs. The FDIC followed with two complementary rulemakings for state-chartered institutions, with comment periods extended to May 18, 2026, while FinCEN and OFAC published a joint proposed rule on anti-money-laundering and sanctions compliance on April 8, 2026. The NCUA and Treasury rounded out the effort with proposals covering credit union affiliates and state regulatory alignment.
Beneath the procedural detail, the core obligations are strict and consistent across agencies:
- Full reserves: every token must be backed one-to-one by dollars or short-term Treasuries, with daily reserve monitoring.
- Fast redemption: issuers must honor valid redemption requests within two business days.
- No hidden yield: the OCC proposal includes a rebuttable presumption against indirect yield-generating arrangements, closing a loophole banks had complained about.
- No deposit insurance: the FDIC has made clear that deposits backing stablecoins will not carry FDIC insurance for token holders, a key distinction from ordinary bank accounts.
Supervision is split by size. As Forbes reported, issuers with under $10 billion outstanding answer to state regulators, while anything larger falls under the OCC. Crucially, no bank can actually issue a payment stablecoin until the rules are finalized and each applicant receives individual supervisory approval, so the deadline marks the start of the licensing era rather than an immediate product launch.
Will JPMorgan and Bank of America actually issue stablecoins?
The largest US lenders have signaled interest for over a year, but their strategies differ. JPMorgan has been operating deposit tokens on its Kinexys platform since June 2025, expanded them to live payments for institutional clients in early 2026, and has placed dollar tokens on Coinbase's Base network. Bank of America CEO Brian Moynihan has been blunt about his intentions, saying "if they make that legal, we will go into that business," while also warning that as much as $6 trillion in deposits could eventually shift to stablecoins if banks stand still.
The incumbents they would challenge are formidable. Tether's USDT held roughly $184.1 billion in circulation as of early July 2026, with Circle's USDC near $73.2 billion, meaning the two largest tokens alone back more than $250 billion. Any bank entrant starts from zero against networks that already move money globally around the clock.
The tokenized deposit counterattack
The most significant July development, however, was not a stablecoin at all. In late July, JPMorgan, Bank of America, Citigroup, and Wells Fargo confirmed they are building a shared tokenized deposit network operated by The Clearing House, the payments company the banks already own. As Forbes detailed, the network would convert commercial deposits into tokens enabling 24/7 interbank transfers, with a target launch in the first half of 2027 and multinational corporations as the initial users. The Clearing House CEO David Watson called it "a big move for the banks," and the operator brings scale: its existing CHIPS system settles about $2 trillion every day.
The legal distinction matters. The GENIUS Act excludes tokenized deposits from its stablecoin licensing requirements, which means they can remain on bank balance sheets and continue funding loans, something a fully reserved stablecoin cannot do. The two models now sit side by side as competing visions for digital dollars:
| Feature | Payment stablecoin (GENIUS Act) | Tokenized deposit |
|---|---|---|
| Issuer | Licensed PPSI (bank or nonbank) | Chartered bank |
| Backing | 1:1 cash and short-term Treasuries | Ordinary bank deposit |
| FDIC insurance for holders | No | Follows deposit insurance rules |
| Can fund bank lending | No, reserves are segregated | Yes, stays on balance sheet |
| Example | USDC, USDT, planned bank coins | JPMorgan Kinexys, Clearing House network |
Competition is arriving from the other direction too. On July 1, 2026, more than 140 companies including BNY, Visa, Mastercard, and Coinbase launched Open USD, a consortium stablecoin expected to go live later this year, setting up a three-way contest between crypto-native issuers, bank consortiums, and tokenized deposits.
What happens next
The months after the deadline will determine how quickly the theory becomes practice. Final rules must be published, then individual applications reviewed, and history suggests caution about bank consortium projects: earlier joint ventures such as we.trade, Marco Polo, and Contour all failed, a track record Forbes notes has bred skepticism about shared bank infrastructure.
Still, the direction is unmistakable. A market that operated for a decade in a regulatory gray zone now has reserve mandates, redemption clocks, and named supervisors. Whether the winners are Tether and Circle defending more than $250 billion in incumbency, banks issuing their own coins under OCC supervision, or a tokenized deposit network that sidesteps the licensing regime entirely, the July 18 deadline marks the moment US stablecoin policy stopped being hypothetical. For banks, the strategic question has shifted from whether digital dollars are coming to which version of them will carry the most volume by 2027.