Has the government picked a winning stablecoin operating model?

No. The GENIUS Act sets who is legally permitted to issue a stablecoin, but the detailed operating rules from the OCC and FDIC remained proposed, not final, as of this brief's verification date, and banks are still deciding which strategic role to pursue.

Why would a bank commit to a strategy before the rules are finalized?

Being an early, credible mover can shape which approach the rest of the market converges on, a real advantage in a coordination game. The tradeoff is the risk of committing to an approach the final rules end up disfavoring.

finance · 2025 to 2026

The Stablecoin Standard Nobody Has Set Yet

A new federal law says who can issue a stablecoin. It does not yet say what the winning operating model looks like, so every bank is placing its bet before the rules are even final.

Facts verified as of July 2026.

The GENIUS Act, enacted by Congress, established the first federal framework for payment stablecoins, generally prohibiting anyone other than a Permitted Payment Stablecoin Issuer from issuing one, and barring digital asset service providers from offering a stablecoin unless its issuer meets that standard or an equivalent one [VERIFIED].

On February 25, 2026, the Office of the Comptroller of the Currency issued a notice of proposed rulemaking running more than 350 pages that establishes uniform standards for becoming a Permitted Payment Stablecoin Issuer, mandating fully backed, bankruptcy-remote reserves, enforceable redemption and liquidity standards, and a rebuttable presumption against indirect yield-generating arrangements [VERIFIED].

Play the same structure: The Issuer Choice.

Sources

[VERIFIED] The OCC issued a notice of proposed rulemaking on February 25, 2026 establishing uniform standards for Permitted Payment Stablecoin Issuers, including reserve, redemption, and liquidity requirements. Office of the Comptroller of the Currency, GENIUS Act Regulations, Bulletin 2026-3
[VERIFIED] The FDIC issued a parallel proposed rulemaking on April 10, 2026 covering FDIC-supervised permitted payment stablecoin issuers and insured depository institutions. FDIC, Notice of Proposed Rulemaking to Establish GENIUS Act Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers
[VERIFIED] Banks requested extended comment periods before the GENIUS Act rules are finalized. CoinDesk, Banks seek to slow down implementation of crypto's GENIUS Act on stablecoin oversight (April 22, 2026)
[VERIFIED] Banks must choose among becoming an issuer, custodian, partner, tokenized-deposit provider, or observer under the GENIUS Act framework. Wolters Kluwer, The GENIUS Act in 2026: A Strategic Inflection Point for US Banks