FDIC Stablecoin Proposal: Reserve Deposits Insured to the Issuer, Not Passed Through to Holders

On April 10, 2026 a proposed rule from the Federal Deposit Insurance Corporation (FDIC) was published in the Federal Register at volume and page 91 FR 18534 under RIN 3064-AG19, its category field reading Notice of proposed rulemaking, that is, a rulemaking proposal. The FDIC Board of Directors had approved it three days earlier, on April 7, 2026; the press release that day said the Board "today approved" it. This article treats the publication date as the event date.

This article was checked on September 17, 2026, reading the full text of the proposal in the Federal Register, the FDIC press release issued with it, the FDIC website's page listing its Federal Register publications and public comments, and a separate reporting forms notice the FDIC published on July 20, 2026. We have tested nothing ourselves and we give no investment or legal advice; every item below is still at the proposal stage, and a final rule may differ from what is proposed.

This is a proposal, not a rule already in force

The document's ACTION field reads Notice of proposed rulemaking, and the first sentence of its SUMMARY field is that the FDIC is soliciting comment on a proposal that would do three things: implement certain requirements of the GENIUS Act applicable to FDIC-supervised permitted payment stablecoin issuers and insured depository institutions, clarify deposit insurance coverage for deposits held as reserve assets for payment stablecoins, and clarify the treatment of tokenized deposits. The proposal itself carries no effective date.

For when the GENIUS Act applies, the proposal cites the statute's own provision: it will become effective on January 18, 2027, or 120 days after the date on which the primary Federal payment stablecoin regulators issue any final regulations implementing the Act, if earlier — that is the law's effective date provision, not this proposal's. The April document does not print the date the Act was enacted; it was a separate FDIC notice of July 20, 2026 that wrote it "was enacted on July 18, 2025".

The comment deadline is given as printed: the DATES field requires comments to be received by the FDIC no later than June 9, 2026. Checked against the FDIC's publications page on September 17, 2026, RIN 3064-AG19 appears only in the row for April 10, 2026, a row marked Comment Period End: June 9, 2026, with no row for a final rule under the same RIN.

Whom it reaches: the depository institutions the FDIC supervises, and their stablecoin subsidiaries

The GENIUS Act sets up four primary Federal payment stablecoin regulators, which the document lists as the FDIC, the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (FRB) and the National Credit Union Administration (NCUA). The FDIC handles only its own part of that: it is the primary Federal payment stablecoin regulator of subsidiaries of insured State nonmember banks and State savings associations approved to issue payment stablecoins, and the document states that such an issuer must be a subsidiary of an insured depository institution (IDI). The other half is custody: the proposed subpart B would apply to persons supervised by the FDIC that are engaged in the business of providing custodial or safekeeping services for payment stablecoin reserves, payment stablecoins used as collateral, or private keys used to issue payment stablecoins. The deposit insurance section has a wider reach: in its impact section, the document lists every insured depository institution maintaining tokenized deposits or deposits held as stablecoin reserves as falling within the direct scope of the proposed rule.

The document also draws its own boundary: the OCC's proposal, published on March 2, 2026, "is more expansive than this proposed rule", and its reach, as the document describes it, also takes in nonbank entities. Using September 30, 2025 as its reference point, the document says the FDIC at that time "supervises zero PPSIs" — it supervises none of these issuers. Checked against the full text of this proposal on September 17, 2026, we saw no provision at all about non-U.S. users, cross-border offering or operators in Taiwan.

Deposit insurance: the issuer is the insured party, not each holder

The FDIC proposes to amend its deposit insurance rules in part 330 so that deposits placed at an insured depository institution as reserves backing a payment stablecoin would be insured to the permitted payment stablecoin issuer (PPSI) under the rules for corporate deposits, and would not be insured to holders on a pass-through basis; the proposed new 12 CFR 330.11(a)(3) is that mechanism. The document explains that the corporate deposit rules add together the corporate deposits of the same depositor at the same insured institution and insure them up to the standard maximum deposit insurance amount (SMDIA), an amount the document writes as "currently $250,000".

The document writes: "In other words, the SMDIA is $250,000 per depositor, per IDI, for deposits held in each ownership category." — the depositor here is the issuer, and it is not that each holder enjoys $250,000 of their own; under the proposed rule, all deposits a PPSI maintains at the same institution would be added together, whether they are reserves or operating expenses, and the FDIC insures only "deposits", so other types of reserve assets fall outside the coverage.

There are two reasons. The first is the statute's own words, which the document quotes: a payment stablecoin shall not be backed by the full faith and credit of the United States, guaranteed by the United States Government, subject to deposit insurance by the Federal Deposit Insurance Corporation, or subject to share insurance by the National Credit Union Administration, and representing otherwise is unlawful. The second is that holders usually settle by transferring the stablecoin, without funds ever leaving that insured deposit account. For tokenized deposits the conclusion runs the other way: the proposed 12 CFR 330.3(k) would state that the technology used for recordkeeping does not affect whether a liability constitutes a "deposit", so the federal deposit insurance the depositor enjoys is unchanged — but the FDIC cautions that not every tokenized bank liability is a deposit.

The proposed requirements a holder would see

The proposed reserve asset requirement is at least one-to-one: an issuer would have to maintain identifiable reserve assets whose value at all times meets or exceeds the total outstanding issuance value of its payment stablecoins, and on each business day it could not let its exposure to any one eligible financial institution exceed 40 percent of its reserve assets. The issuer would also have to publish monthly, on its own website, the number of coins outstanding and the composition of its reserve assets as of the close of business on the last day of the previous month, and that monthly report would have to be examined by a registered public accounting firm.

On redemption, the FDIC proposes to define "timely" as no later than two business days following the date of the requested redemption, states plainly that this is a ceiling and that an issuer may be faster, and at the same time acknowledges that the market may expect redemptions far more quickly than that, so it seeks comment on whether the number of days is appropriate. A significant redemption request would be defined as aggregate redemption requests exceeding 10 percent of an issuer's outstanding issuance value within a single 24-hour period. The proposed provision would require an issuer to redeem any number greater than or equal to one payment stablecoin, but the text then adds one qualifier: subject to appropriate screening and onboarding. Fees would have to be disclosed, and an increase would require at least seven calendar days' prior notice; an issuer also could not pay a holder any form of interest or yield solely in connection with the holding, use or retention of the stablecoin.

And if the issuer fails? The proposal gives holders no deposit insurance style guarantee of repayment, but it does address priority of claims: the FDIC's approval authority extends only to activities that would not jeopardize the claims of payment stablecoin holders in the insolvency proceedings described in section 11 of the GENIUS Act, and those claims would rank senior to claims of non-payment stablecoin creditors.

What is still unsettled, and how to check the current status yourself

Almost every number in the proposal is still out for comment: the document's questions run all the way to Question 144, and Question 125 asks whether the FDIC's proposed treatment of deposits comprising stablecoin reserves is appropriate and whether it is the best reading of the GENIUS Act and the Federal Deposit Insurance Act. There has been follow-up as well: on July 20, 2026 the FDIC separately published a notice seeking comment on the weekly and quarterly reporting forms proposed in this rulemaking, under OMB control number 3064-0225, with a printed deadline of September 18, 2026 — a different comment period from the April proposal's June 9 deadline.

What follows is an editorially designed example, not a test. Suppose someone receives a dollar stablecoin through some cross-border service and assumes the balance is insured the way a bank deposit is: under what this proposal would do, and within the scope it reaches, what is insured is the reserve deposit the issuer holds at the bank, counted as a corporate deposit and added together with the issuer's other corporate deposits there, rather than each holder being insured separately. To see how far the proposal has got, go to the FDIC's page of Federal Register publications and public comments, find the row for April 10, 2026 with RIN 3064-AG19, and look at whether an additional row for a final rule under the same RIN has appeared beside it. We do not compare or recommend any stablecoin, exchange, wallet or issuer.

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