GENIUS Act, Year One: Zero Final Rules, One Working Consortium

The GENIUS Act turned one year old on July 18, and two things happened in those twelve months that point in opposite directions.

The law told federal regulators to write the rules within a year. They did not. Eleven proposals exist. No final rule does.

In the same twelve months, a group of community banks that started with nothing built a funded entity, signed up more than fifty banks, filed formal asks with the agencies, and picked its vendors.

For a community bank, the pace of those two records is the story of the year, more than the technology either one is building.

By the numbers

0

final GENIUS Act rules, twelve months in.

The deadline that passed

The GENIUS Act became law on July 18, 2025, and set a federal framework for payment stablecoins: licensed issuers, full reserve backing, and no yield paid to holders. It also set homework. Each primary federal payment stablecoin regulator had one year from enactment to issue implementing regulations.¹

That year ended eleven days ago. What exists instead is a stack of drafts.²

What twelve months of rulemaking produced

Eleven rulemakings, in order, plainly:³

• September 19, 2025. Treasury opens with an advance notice on how payment stablecoins are issued and treated. An advance notice is a request for ideas, not a draft rule.
• December 19, 2025. The FDIC proposes the application process for subsidiaries of the banks it supervises. Its comment period gets extended into May.
• February 12, 2026. The NCUA proposes licensing and investment rules for credit-union-affiliated issuers.
• March 2, 2026. The OCC issues two proposals on the same day: capital, liquidity and risk management, and its general regulations and application process.
• April 3, 2026. Treasury proposes the principles a state regime must meet to be treated as substantially similar to the federal one. Comments closed June 2.
• April 10, 2026. Two more land: Treasury on anti-money-laundering and sanctions compliance, the FDIC on capital, liquidity and risk management.
• May 18, 2026. The NCUA proposes its capital, liquidity and risk management rule.
• June 6, 2026. The FDIC proposes Bank Secrecy Act and sanctions compliance. Comments are open through August 4, 2026.
• June 22, 2026. A FinCEN-led interagency proposal on Customer Identification Program requirements for permitted payment stablecoin issuers. Comments are open through August 21, 2026.

Read that list twice and the problem shows itself. Two comment windows are still open. Nothing can be finalized in those two areas until they close, and finalizing takes months after that. And in July, the American Bankers Association and other trade groups asked the agencies to align their implementations with each other, which is the polite way of saying four regulators are drafting four frameworks for one statute.⁴

None of this is scandal. Financial rulemaking is slow, comment periods exist for good reasons, and a rushed rulebook on reserve requirements would be worse than a late one. But a bank cannot build a product against a proposal. It cannot get a board to approve capital against a proposal. It cannot ask its core provider for anything on the strength of a proposal.

The date that does not move

This is the part for the board packet.

The Act takes effect on the earlier of two dates: January 18, 2027, or 120 days after the regulators issue final rules.¹ That structure was written on the assumption the rules would arrive early. They did not. Any final rule issued after roughly September 2026 leaves January 18, 2027 as the binding date.

So the arithmetic now runs one way. The statute becomes effective in under six months whether or not the rulebook is finished. Banks get a live law and a draft framework at the same time.

That is the environment your 2027 plan is being written in. Not "we will know more when the rules come out." The rules may well come out after the law is already in force.

What twelve months of consortium produced

Now the other clock.

The Independent Bankers Association of Texas launched its tokenized deposit consortium in late 2025 and funded a dedicated entity, DTX, LLC, to run a pilot for an interbank tokenized deposit network, banker-owned and banker-controlled. Membership passed 40 banks on April 28, 2026, and more than 50 by June 15. In July 2026 DTX named its technology partners: Rimark, whose Solstice Protocol handles settlement for deposits that stay on the issuing bank's balance sheet, plus Infinant and Privacy Lock. Project CODA is the governance layer the member banks run themselves.⁵

If tokenized deposits are new to you, the mechanics are in our July 21 explainer.⁷ The short version: a tokenized deposit is your bank's own deposit made programmable, still on your balance sheet, as opposed to a stablecoin, which is money that has left the banking system.

The consortium also did something less visible and more useful. In April 2026 it asked the agencies for three specific things: model-risk and operational-risk treatment of tokenized deposit products, supervisory requirements tiered to community bank scale rather than money-center scale, and mandated open API access to deposit data held by core banking providers.⁶

No rule on the current list touches that third ask. Every one of the eleven proposals above governs issuers, reserves, capital, and compliance. None of them governs whether your core processor will let your own deposit data out at a price you can pay. For most banks in the $100M to $2B range, that is the actual gate, and the federal rulebook will not open it whenever it is finished.

Why the gap matters to your funding

This reads like a Washington story and lands as a funding story.

Deposits are what you lend against. The premise behind both tokenized deposit networks is that money which cannot settle instantly, at 2 a.m., with rules attached, will eventually lose ground to money that can. If that premise holds even slightly, the deposits most exposed are business operating accounts, the same accounts this publication keeps arguing are worth the most to defend.

The rulemaking delay does not pause that. It just means the competitive clock and the regulatory clock are running at different speeds. The banks that spent the last twelve months waiting for clarity have twelve months of eleven proposals to show for it. The banks that spent the last twelve months in a consortium have a seat, a governance vote, and a set of questions already filed with their regulators.

Neither group has a live product yet. Only one of them is positioned to move the week the rules land.

The honest unknowns

We publish limits next to claims, so here are this piece's.

The rules could go final quickly. Comment windows close in August, and agencies sometimes move faster than anyone expects when a statutory deadline has already slipped. If a coordinated final package lands in September, the 120-day clock could pull the effective date forward and this article's arithmetic changes.

DTX is a pilot, not a network. Pilots exist to find problems, and no one outside the consortium has seen its results.

The demand question is still open. Nobody has proven that community bank business customers will pay for programmable deposits. The evidence so far is that the largest banks in the country decided they could not afford to find out late.

And "no final rules" is a claim with a date on it. We verified it against public rulemaking trackers on July 29, 2026. If an agency finalized something in the days around this publication, the record moves and we will update this page.

What to do before January 18, 2027

Four things, none of them expensive.

1. Put the effective date on a board calendar. Not the rules, the date. January 18, 2027 arrives whether or not the framework is finished.
2. Ask your core provider in writing what API access to your own deposit data costs and what their tokenized deposit roadmap is. DTX has told the regulators this is the chokepoint. Find out where you stand on it before you need to know.
3. Read the two open proposals that touch you: the FDIC's Bank Secrecy Act and sanctions proposal and the interagency Customer Identification Program proposal. Both are still open for comment as of this writing, and a community bank comment costs a letter.
4. Decide whether information is worth a consortium seat. So far, DTX membership has bought member banks a voice in the rulebook more than it has bought them technology. That may be the better purchase anyway.

What not to do is buy anything. There is no finished network to buy, in either camp.

Methodology

This piece compares two public records over the twelve months from July 18, 2025 to July 18, 2026: federal GENIUS Act rulemaking, and the public announcements of the IBAT DTX consortium. Rulemaking dates and statuses come from public trackers and agency notices reviewed July 29, 2026, and every proposal is dated in the text. The claim that no final rule exists is a statement about the public record on that review date, not a prediction. The Deposit Report has no relationship with IBAT, DTX, any agency, or any vendor named here. We update this page as the record changes.