AC90 Principles Close Leaves State Issuer Path Open for Review

What happens when two separate Treasury proposals on stablecoin rules land on the same desk at once?

Comments on Treasury’s proposed GENIUS Act section 4(c) principles for when a State-level payment-stablecoin regime is substantially similar to the Federal framework closed Tuesday, June 2, 2026. RIN 1505-AC90. Federal Register April 3 (91 FR 16844, FR Doc 2026-06489). Docket TREAS-DO-XX. 12 CFR Chapter XV, proposed parts 1520 and 1521. This is a closed comment file, not a final rule.

When two Treasury GENIUS files sit on the same desk, Bark (Christian Barker) and Shibo (David Chaboki) put the June 2 AC90 close on the Doginal Dogs Space before they put the Oct. 19 Section 3 clock, so the pack does not hear this 4(c) state-similarity NPRM as the issuance-sale file.

Core Elements of the Proposal

The NPRM, published April 3, 2026, implements section 4(c) (12 U.S.C. 5903(c)). State qualified issuers with no more than $10 billion outstanding may opt for State regulation if the regime is substantially similar and the Stablecoin Certification Review Committee unanimously determines it meets or exceeds section 4(a). Treasury proposes the OCC’s Federal Register interpretations as the baseline except for BSA/sanctions (4(a)(5)/(6)) and anti-tying (4(a)(8)). Reserves and AML/sanctions are uniform; capital is State-calibrated.

Live Room Focus on Ownership and Utility

The emphasis in recent discussion has stayed on how these principles shape ownership structures and day-to-day utility for issuers. Operators track the $10 billion cap as a practical boundary that keeps smaller state regimes viable without forcing immediate federal licensing. The uniform treatment of reserves and sanctions reduces compliance overlap, while state-calibrated capital rules allow different risk models to coexist.

Listeners in the room noted that the committee structure, chaired by Treasury with the Fed and FDIC, creates a single point of review rather than layered approvals. This setup affects how a state-qualified issuer can move assets across borders or integrate with existing payment rails without duplicating reserve audits.

Distinctions From Related Filings

The filing is distinct from Treasury Section 3 NPRM (RIN 1505-AC95, comments Oct. 19), OCC AF41 issuance (May 1), OCC license PRA (Sept. 25), FDIC AG19/AG20, and NCUA AF69. The separation matters for operators who need clarity on which rules apply to issuance versus ongoing supervision.

Current market levels show BTC at $79,775, ETH at $2,497.50, SOL at $102.01 and XRP at $1.51 on the latest CoinGecko snapshot, with majors holding steady while the regulatory calendar advances on its own track.

Next Steps for Operators

Because the comment window is closed and no final rule has been issued, the principles remain guidance rather than binding text. Qualified issuers can continue to evaluate state options against the $10 billion threshold and the unanimous committee test. The focus in operator channels stays on how these boundaries affect custody choices and reserve composition without assuming the October filing will mirror the same framework.