Debevoise & Plimpton LLP has published a guide on the GENIUS Act, and the OCC and FDIC proposed rules, including our observations on key issues and on the potential implications and opportunities for the banking industry. The key takeaways from the guide, which was authored by lawyers from the firm’s Banking and National Security Groups, are:

• the GENIUS Act, signed into law on July 18, 2025, establishes the first federal statutory framework for payment stablecoins, introducing licensing, reserve, disclosure and compliance requirements for permitted payment stablecoin issuers;
• the OCC and FDIC have issued proposed rules to implement aspects of their respective responsibilities under the GENIUS Act. While the proposed rules largely align with the statute, they would have significant policy implications for payment stablecoin issuers. Many questions remain open, and the framework is likely to evolve through the comment process and interagency coordination; and
• stablecoin-related strategic opportunities for banks are likely to be shaped by supervisory expectations, the implementation of the new statutory and regulatory framework and the continued development of their risk-management and control capabilities.