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Treasury Should Preserve State-Federal Parity in Stablecoin Regulation

October 20, 2026 / Source: CSBS

Washington, D.C. – The U.S. Department of the Treasury’s proposed rule to implement the GENIUS Act’s safe harbor provision threatens parity between state and federal stablecoin issuers, the Conference of State Bank Supervisors (CSBS), the National Conference of State Legislatures, the National Association of State Credit Union Supervisors, and the Money Transmitter Regulators Association said in a comment letter submitted today.

The proposed rule should provide state-approved issuers with transition protections equivalent to those available to federal issuers, allowing both to operate without disruption when the law takes effect on Jan. 18, 2027. 

The letter recommended that Treasury:

  • Clarify that state-approved stablecoin issuers may continue operating while the Stablecoin Certification Review Committee reviews its approving state’s certification and during any period provided to cure an initial denial.
  • Provide a safe harbor for issuers operating in states that file conditional certifications indicating that compliant state laws will be in place by Jan. 18, 2028.

Statement from CSBS President and CEO Brandon Milhorn:

“Congress deliberately preserved both state and federal pathways to protect consumer choice and support a resilient, innovative stablecoin market. Treasury should honor that framework by unequivocally providing state-approved issuers the same transition protections available to federal issuers.”

Read more about why Treasury should provide greater certainty and parity for state stablecoin issuers.

Read CSBS statements and comments on the GENIUS Act: