Banking and Finance Law Daily Wrap Up, FINANCIAL TECHNOLOGY—Treasury issues Stablecoin Certification Review Committee interim final rule, (Sep 29, 2026)

By Sherri M. Schroeder, J.D.
The regulations prescribe the certification form and set out a process to facilitate the Committee's approval or denial of the certifications submitted by state payment stablecoin regulators under the GENIUS Act.
The U.S. Department of the Treasury has issued an interim final rule, effective Sept. 30, 2026, that sets out the process by which the Stablecoin Certification Review Committee will approve or deny certifications submitted by state payment stablecoin regulators under section 4(c)(4) of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The interim final rule also prescribes the form for such certifications. The rule will ensure that interim forms and procedural regulations are in place to facilitate certification submission by the effective date of the GENIUS Act, but the Committee intends to revise these forms and procedural regulations, as appropriate, following its consideration of comments. Comments are due by November 30.
The GENIUS Act was enacted on July 18, 2025. It provides a framework for the federal regulation of payment stablecoins. It also asks federal agency regulators to fill out that outline by providing an appropriately tailored regime to protect consumers, mitigate potential illicit finance risks, and address financial stability risks.
Section 4(c) of the GENIUS Act states that state-qualified payment stablecoin issuers with a consolidated total outstanding issuance of payment stablecoins of not more than $10 billion may opt for state regulation provided that the state payment stablecoin regulator has submitted a certification and attestation and the Committee has approved the state-level regulatory regime and determined that it meets or exceeds the standards and requirements described in Section 4(a) of the GENIUS Act. The interim final rule prescribes the form of certifications and implements the procedures necessary for the Committee to carry out its statutory review responsibilities. To draft these procedures, the Committee considered comments received on the advanced notice of proposed rulemaking relating to implementation of the GENIUS Act (see Banking and Finance Law Daily, Sept. 18, 2025).
The interim final rule sets out the procedures by which the Committee will review state “substantial similarity” certifications and recertifications under section 4(c) of the GENIUS Act, addressing the manner of the submission and setting out the form of initial certifications. According to the interim final rule, approval of a state's certification will be suspended if an annual recertification is not timely filed.
Because the Committee recognized that states may need additional time for the state-level regulatory regime to appropriately reflect any changes to federal statutes, interpretations, regulations, or orders, the Rule also provides that the cure period is two years from the date of enactment of an Act of Congress or two years from the date of publication of the regulatory materials.
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