Stablecoins: The Fed offers 2 days to reimburse

On September 24, 2026, the American Federal Reserve (Fed) proposed a reimbursement of stablecoins within two business days for the issuers it supervises. The project provides for exceptions and remains subject to consultation. This deadline therefore does not yet constitute an obligation applicable to all dollar stablecoins.

The text published in the Federal Register on September 29 specifies the Fed’s rules for stablecoins: repayment, reserve and capital. It implements the GENIUS Act, the provisions of which Tremplin.io presented at the Senate voting stage. A second proposal organizes the approval of the banking subsidiaries concerned.

Stablecoins: two business days according to the Fed, with exceptions

A stablecoin aims to maintain a stable value in relation to a reference asset, in this case a currency. Its reimbursement consists of obtaining this value from the issuer. It differs from a sale on a platform, the price of which depends on the market.

The project sets the normal deadline at two working days after the date of the request. It aims for reimbursement by the issuer or its representative, not exchanges between buyers and sellers. A quick transfer on a blockchain and a reimbursement in currency are two different operations.

Section 247.12 nevertheless provides for exceptions. Identity or sanctions compliance checks may require additional time. A delay independent of the issuer may also be permitted, subject to reasonable efforts to resolve it. A simple increase in the number of requests is not enough to justify this exception.

The Fed could, for its part, extend the deadline to protect the soundness of the issuer, financial stability or the public interest.

Reserves and capital required by the Fed for stablecoins

The value of reserve assets should cover at least 100% of the face value of stablecoins in circulationat any time. For every $1 billion in tokens issued, that’s at least $1 billion in eligible assets.

THE Fed staff memo cites dollar cash and balances with the Fed. It admits U.S. Treasury securities with a remaining maturity of 93 days or less. Deposits with insured institutions and certain investments guaranteed by Treasury securities would be permitted. A deposit with an insured bank may exceed the insurance limit.

The capital would be used to absorb losses. The component linked to the volume of issue would start from 2% on the first 20 billion dollars. It would increase to 1.5% over the next 30 billion, then to 1% beyond that. This scale does not summarize the total requirement: certain non-reserve income, operational losses and credit risks also come into play. The complete calculation appears in sections 247.15 to 247.18 of the project.

The ban on interest would also be targeted. The issuer could not remunerate the sole holding, use or conservation of its stablecoin. The text extends to certain arrangements with third parties, without prohibiting all paid services using stablecoins.

Fed rules do not cover all stablecoin issuers

The prudential rules described concern authorized subsidiaries of state-chartered banks that are members of the Fed and whose deposits are insured. They extend to certain state-chartered, uninsured depository institutions that transition to the federal system. A provision in the draft on tied sales would have a broader scope, covering all authorized issuers.

For other actors, the competent authority depends on their status. Two examples show why the stablecoin’s trade name is not enough. According to Tether’s announcement of January 27, 2026USA₮ is issued by Anchorage Digital Bank. This token for the US market is separate from USDT.

Circle announced on July 10 the final approval of its national fiduciary bank by the OCC, the supervisor of national banks. The announcement first describes an asset conservation activity, with reserve management considered later. It does not, on its own, allow us to conclude that the issuance of USDC is now the responsibility of this bank.

The market goes well beyond the scope of the Fed alone. According to ChallengeLlamaaccessed October 5, 2026, its capitalization reached approximately $307.1 billion. USDT accounted for 184 billion, and USDC 74.2 billion.

MiCA guarantees a right to reimbursement according to another framework

Facing the Fed project on stablecoinsthe relevant European comparison concerns electronic money tokens, or EMT, which refer to a single official currency. It does not extend indiscriminately to all crypto-assets qualified as stablecoins.

Point compared	Fed plan for affected issuers	MiCA for EMTs
Refund	Two working days after the date of the request, with exceptions	Right to reimbursement at any time and at par, according to article 49
Cover assets	Eligible assets covering at least the face value of the tokens	Article 54 provides for at least 30% of funds in separate accounts with credit institutions; the balance in safe, liquid and low-risk assets
Interests	Prohibition targeting the issuer for sole possession, use or conservation; certain arrangements with third parties are also covered	Prohibition for issuers and service providers of crypto-assets, according to article 50

The European threshold of 30% does not constitute an overall coverage rate of 30%. It concerns the distribution of funds. Additional requirements apply to electronic money institutions issuing EMT of significant importance, according to section 58.

The threshold of 10 billion comes from the law

The 10 billion threshold does not come from the Fed’s rules on stablecoins, but from the law. The GENIUS Act opens a path for state oversight. It concerns issuers whose consolidated outstandings do not exceed $10 billion, if the local regime is certified. Transition and derogation mechanisms exist beyond the threshold.

There interim rule published by Treasury on September 30 organizes the examination of these certifications. It does not create this threshold. It came into force that day. The text, however, conditions the acceptance of certifications on administrative approval of the collection of information.

The debates also concern the effective protection of holders. The governor Michael Barr supports the Fed’s proposal on stablecoins, while asking for clarification of redemption rights. He criticizes the criterion which limits certain supervisory interventions to anti-money laundering failures deemed significant or systemic.

Stablecoins will only be stable if they can be redeemed reliably and quickly, at par, under various circumstances.

Federal Reserve Governor Michael Barr declaration of September 24, 2026

Regulation of issuance accompanies a broader debate about the effects of stablecoins on monetary policy. In terms of timing, Jonathan Gould announced in August that the OCC planned to publish its final rule by November. This is an announced schedule, not an acquired adoption. The Fed’s consultation on stablecoins ends on November 30, 2026. The GENIUS Act will take effect no later than January 18, 2027. It may apply sooner, 120 days after final federal rules are adopted. Some provisions have their own timetable.