Bank trade groups push FDIC and OCC to align stablecoin rules before the GENIUS Act clock starts

A new round of comments on U.S. stablecoin rulemaking is drawing attention to a problem that could matter as much as any reserve ratio or custody standard: whether the federal agencies writing the post-GENIUS Act rulebook are actually moving in sync. Banking trade groups led by the American Bankers Association are pressing the Federal Deposit Insurance Corporation to align its framework with the Office of the Comptroller of the Currency and the other primary stablecoin regulators before final rules are issued. Their argument is that stablecoin oversight will be harder to enforce, easier to arbitrage and more confusing for end users if materially different standards are allowed to harden across agencies.

The immediate backdrop is the FDIC’s April 10 notice of proposed rulemaking on requirements and standards for FDIC-supervised permitted payment stablecoin issuers and insured depository institutions. According to the agency’s rule summary, the proposal is meant to implement GENIUS Act requirements for FDIC-supervised issuers, clarify how deposit insurance applies to reserve deposits backing payment stablecoins, and confirm how tokenized deposits should be treated under existing banking law. That is a consequential package on its own, because it touches reserve management, consumer disclosures and the boundary between bank deposits and stablecoin liabilities. But commenters are increasingly treating it as one piece of a broader federal architecture rather than a stand-alone banking rule.

That broader architecture is where the timetable risk appears. In its June comment letter on the FDIC proposal, the ABA said the statute becomes effective on the earlier of January 18, 2027 or 120 days after final implementing regulations are issued by the primary federal payment stablecoin regulators. The group argued that the law is ambiguous on whether one regulator acting alone could start that countdown, creating the possibility that the GENIUS Act could switch on before the rest of the interagency framework is complete. That is a meaningful concern for institutions that may need to stand up issuance, reserve, disclosure and compliance systems across multiple supervisory lines at the same time.

The other live issue is definitional, not procedural. The ABA’s letter says the FDIC and OCC have proposed materially different definitions of “customer,” and that the difference is not cosmetic. In the banking groups’ reading, the FDIC proposal ties the term narrowly to people dealing directly with a permitted payment stablecoin issuer, while the OCC’s formulation is broader and not limited to a direct issuer relationship. The trade groups warn that this split affects who benefits from core consumer-protection obligations, who receives disclosures tied to redemption and fees, and how secondary-market stablecoin users are handled. In practice, that means two economically similar stablecoin products could face different compliance expectations depending on charter type, which is exactly the sort of regulatory arbitrage the groups say Congress was trying to avoid.

On substance, the banking lobby is not opposing everything in the FDIC draft. The ABA explicitly backed the agency’s proposed clarification that reserve deposits held at FDIC-insured institutions should be insured to the stablecoin issuer as corporate deposits rather than on a pass-through basis to individual token holders. That position would not give stablecoin holders deposit insurance simply because they hold a token backed by insured-bank reserves, and the trade group said any final rule should pair that treatment with clear disclosure at the point of purchase. For the market, that matters because the next phase of stablecoin adoption will depend not just on redemption mechanics but on whether issuers, distributors and wallets describe legal protections accurately.

The OCC’s own rulemaking helps explain why banks want a coordinated finish. In Bulletin 2026-3, issued in February, the OCC laid out a proposed framework spanning issuer activities, reserve assets, redemption, risk management, audits, custody, applications and supervision. That scope is broader than a narrow operational checklist; it is the skeleton of a federal banking regime for tokenized dollars. If FDIC-supervised issuers and OCC-supervised issuers end up operating under different terminology or implementation dates, market structure decisions could drift toward whichever charter appears easier to navigate instead of whichever structure best matches the underlying business and risk profile.

For RWA markets, the stakes are larger than stablecoins alone. Tokenized cash, tokenized deposits and short-duration treasury products all rely on credible settlement assets and legally durable redemption rails. A fragmented rulebook would not stop issuance, but it could slow institutional rollout, complicate reserve segregation and make distributors more cautious about how they market onchain dollars to corporate and retail users. A harmonized interagency framework, by contrast, would not settle every open question around bank-issued stablecoins, yet it would give issuers and investors a clearer operating map at a moment when tokenized money is becoming core infrastructure for the broader real-world asset stack.