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FollowingThe Treasury Department issues final interim rules on the GENIUS Act certification process
The U.S. Treasury Department recently issued final interim rules establishing the stablecoin issuer certification process required by the GENIUS Act. Under the framework, eligible state-level payment stablecoin issuers with issues of no more than $10 billion can choose to accept state-level supervision if each state's regulatory regime is determined to be "substantially similar" to the federal framework.
This rule makes US$10 billion one of the most important dividing lines in the emerging U.S. stablecoin market.
State regulation requires federal approval
States cannot simply set their own stablecoin rules and start supervising issuers. Regulators must submit certification applications to the "stablecoin Certification Review Committee" detailing how their laws, regulations and enforceable guidelines comply with federal standards. The committee is chaired by the Secretary of the Treasury and also includes representatives of the Federal Reserve and the Federal Deposit Insurance Corporation (FDIC).
Approval of initial certification requires the committee to unanimously determine that the state's regulatory framework meets or exceeds the standards of the GENIUS Act. After that, states must also submit annual recertification.
This structure is built on the broader regulatory framework of U.S. stablecoin, which is increasingly prompting stablecoin issuers to shift to bank-like supervision and compliance models.
US$10 billion could be a regulatory turning point
The importance of this threshold is that it creates different regulatory paths based on the size of the issuer. Smaller issuers may remain under approved state regulatory regimes, while larger stablecoin companies will eventually have to move away from relying solely on state regulatory regimes. Treasury rules clearly require that state frameworks include procedures for transitioning to federal oversight.
This means that the expansion of regulatory scale may itself become part of a stablecoin company's growth strategy. When a company's outstanding tokens approach $10 billion, its focus will no longer be limited to reserves, distribution channels and payment functions, and will also need to be prepared for a potentially different regulatory system.
Coinpaper's analysis of stablecoin reserves points out that once issuers reach billions of dollars, reserve management, redemption liquidity and asset custody will become more systematically important.
