Invest12 publishers2 min readPublished Updated
Fed drafts rules that would make stablecoin issuance a supervised bank business
Federal Reserve proposes full reserves for stablecoins it supervises and prior approval for bank issuers, opening 60 days of comment. Still open are when a bank's 120-day approval clock can restart and whether a bank consortium may file once.
The Investor · Invest desk

What happened
- The Federal Reserve board voted unanimously on September 24, 2026 to approve two stablecoin proposals, the last of four primary prudential regulators to set out reserve and capital rules.
- Board-supervised issuers would add a capital surcharge to 1:1 reserves: 2% on the first $20 billion outstanding, 1.5% on the next $30 billion and 1% above $50 billion.
- Issuers would generally have to meet redemption requests within two business days, the standard the OCC and FDIC set in their earlier proposals.
- Governor Michael Barr signaled that the proposals, though necessary, may leave the most dangerous run scenario unaddressed, TechTimes reported.
- A 60-day comment window opens on Federal Register publication, ahead of the January 2027 statutory effective date.
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Why it matters
- cost An issuer the size of Circle's USDC, about $73 billion, would need roughly $1.08 billion of surcharge capital before credit and operational risk charges, funded alongside full reserves.
- constraint A new issuer pays 2 cents of capital per coin until it reaches $20 billion, while an incumbent's coins past $50 billion cost 1 cent, so a dollar of entry costs twice a dollar of growth at the top.
- exposure Chief executives and finance chiefs would put their own certifications on audited monthly reserve reports, a standard more common in public-company filings than among crypto-native issuers.
Run the tiers on an issuer with $50 billion outstanding and the surcharge comes to $850 million: $400 million on the first $20 billion at 2%, plus $450 million on the next $30 billion at 1.5% [1]. TechTimes, which reported the proposal, put that issuer's minimum at roughly $1.15 billion, including $100 million on the portion above $50 billion [9]. An issuer at exactly $50 billion has no such portion. The report's own three line items add to $950 million [2], and $1.15 billion is what the schedule produces at $80 billion outstanding [3].
Larger floats show the schedule's shape. An issuer the size of Tether's USDT, about $184 billion by the report's count [10], would owe roughly $2.19 billion, an effective rate near 1.19% [4]. A flat 2% on the same float would be $3.68 billion [5]. The Fed chose a charge that falls with size, or rather one whose marginal rate halves between the first dollar issued and anything past $50 billion [5]. The proposal reaches state member banks and their stablecoin-issuing subsidiaries [4], so the USDT figure is an illustration of scale.
According to TechTimes, the surcharge is designed to absorb operational losses [6], and separate charges cover credit and operational risk [7]. A run is a liquidity problem. Holders want dollars faster than reserves turn into cash. The proposal answers that with reserves in short-term Treasury bills and other high-quality liquid assets [8], and with a trigger that forces an under-reserved issuer to notify the Fed immediately, submit to a remediation plan, or liquidate and redeem every coin [12]. Against a $50 billion float, the $850 million surcharge comes to 1.7 cents per coin [7].
TechTimes' summary of Barr's warning does not say which run scenario he meant [14]. The board approved both proposals unanimously [1], so his concern came with a yes vote.
Three outcomes look plausible from here. Issuers use the 60 days to argue the tiers down; Barr's concern pulls a run-specific liquidity rule into the final version; or the Fed finalizes close to the draft to hold the January 2027 date [15]. I'd expect the third. The Fed's two-day redemption clock already matches its peers' [11], and the FDIC aligned its reserve composition with the OCC's [16], so the drafts are converging. The counter-case is that the regulators have already missed the statute's one-year deadline once [2], which makes a second slip to add a run provision cheap. A final rule with a separate run requirement, or with moved breakpoints, would show that expectation was wrong.
What to watch
- Whether the final rule adds a liquidity requirement aimed at runs beyond 1:1 reserves and the two-day redemption clock.
- Comment letters from state member banks and their issuing subsidiaries on the 2% rate covering the first $20 billion.
- Whether Barr publicly specifies which run scenario he thinks the proposals leave uncovered.