The Federal Deposit Insurance Corporation has filed proposed information-collection forms for FDIC-supervised permitted payment stablecoin issuers under its GENIUS Act implementation framework. The proposal is scheduled for Federal Register publication on July 20, 2026, followed by a 60-day comment period.

The GENIUS Act established a federal framework for the regulation of payment stablecoins — digital assets designed to maintain a stable value relative to a reference asset (typically the U.S. dollar) and used primarily for payment purposes. Under the GENIUS Act, FDIC-supervised institutions that issue permitted payment stablecoins are subject to FDIC oversight, including the reporting requirements now proposed.

The FDIC's proposal creates a tiered reporting framework based on issuer size.

Issuers meeting either of the following thresholds would submit a detailed weekly report:

• At least $1 billion in outstanding stablecoins, or
• At least $100 million in average daily transaction volume during the preceding month

The detailed weekly report would require disclosure of:

• Reserves — composition, valuation, and custodial arrangements
• Redemptions — volume, timing, and settlement data
• Issuance activity — new issuance, burns, and net changes
• Major holders and exchanges — concentration data and exchange relationships
• Treasury and cash positions — breakdown of reserve assets by type
• Derivatives — any derivative positions related to reserve management
• Capital — capital adequacy data
• Custody arrangements — details of custodial relationships and segregation
• Operational backstops — liquidity facilities, credit lines, and contingency arrangements
• Balance-sheet data — consolidated financial position

Issuers below the large-issuer thresholds would submit an abridged weekly form with a reduced set of data points.

All covered issuers — regardless of size — would submit quarterly financial and operational reports resembling regulatory call reports. These quarterly filings would provide a comprehensive snapshot of the issuer's financial condition, operational capacity, and compliance posture.

Stablecoin issuers should immediately assess whether their treasury, reserve, reconciliation, and transaction-monitoring systems can produce weekly regulator-ready data. Key questions include:

• Can the issuer produce a complete reserve composition report on a weekly basis?
• Are redemption and issuance data captured in real time or with a lag?
• Can the issuer identify and report major holders and exchange concentrations weekly?
• Are custody arrangements documented in sufficient detail to satisfy the proposed disclosure requirements?
• Does the issuer have the operational capacity to produce quarterly call-report-style filings?

Issuers that cannot currently produce this data on the required cadence should begin technology and operational remediation immediately, given the lead time required to build or procure compliant reporting infrastructure.

Banks that sponsor stablecoin issuers — whether as the issuing entity itself or as a partner institution — should assess their data-sharing obligations with the issuer and their own regulatory reporting obligations. Sponsoring banks may need to provide issuers with access to reserve, custody, and transaction data on a weekly basis.

Custodians holding stablecoin reserves should review their data-access and reporting capabilities. The proposed requirements contemplate detailed weekly disclosure of custody arrangements, reserve composition, and segregation. Custodians should assess whether their systems can produce this data and whether their agreements with issuers require them to do so.

Exchanges that list or facilitate trading in covered stablecoins should assess whether they will be required to provide concentration and transaction-volume data to issuers for inclusion in weekly reports. Existing data-sharing agreements with issuers may need to be amended.

Fintech companies and technology vendors providing infrastructure to stablecoin issuers should assess whether their platforms can support the data extraction, aggregation, and reporting functions required by the proposed framework. Vendors may need to build new reporting modules or APIs.

Institutional counterparties — including money-market funds, corporate treasurers, and payment processors that hold or transact in covered stablecoins — should assess the operational and counterparty-risk implications of the proposed reporting requirements. Enhanced transparency may affect pricing, liquidity, and risk-management decisions.

Agreements with custodians, reserve managers, technology vendors, and exchanges may need to be amended to include:

• Enhanced data-access provisions — requiring counterparties to provide the data needed for weekly and quarterly reports
• Audit rights — permitting the issuer (and potentially regulators) to verify data accuracy
• Record-retention requirements — ensuring that underlying data is preserved for the required period
• Regulatory-reporting cooperation provisions — requiring counterparties to cooperate with FDIC examinations and information requests

The proposal is scheduled for Federal Register publication on July 20, 2026, followed by a 60-day comment period. Stablecoin issuers, sponsoring banks, custodians, exchanges, fintech companies, and industry associations are encouraged to submit comments addressing the proposed reporting requirements, data definitions, thresholds, and implementation timeline.

This alert is provided for informational purposes only and does not constitute legal advice. For guidance on how the FDIC stablecoin reporting proposal may affect your specific compliance obligations, please contact ULF New York.