The $10 Billion Line: Treasury Drops the First GENIUS Act Rule

On September 30, Treasury issued the first immediately-effective rule under the GENIUS Act, splitting the stablecoin market into federal and state tracks, with Tether and Circle shut out of the state pathway by the $10 billion threshold — the stablecoin endgame is shifting from legislative debate to regulatory action.

There is deeper market logic behind this pricing mechanism. The American Bankers Association (ABA) has raised concern that if a state regime is deemed “substantially similar” but allows issuers to engage in activity beyond the scope defined by the GENIUS Act, a regulatory arbitrage window could open that the SCRC must police through annual recertification. The committee’s power to deny recertification on the basis of a “material change” or a “significant change in circumstances” provides a correction mechanism, but it also layers persistent uncertainty onto state-regulated issuers. Looking ahead, January 18, 2028 is the deadline for initial state certification, while states that had prudential regimes in place before January 14, 2026 will benefit from an expedited timeline. The industry is currently in a holding pattern while the “substantial similarity” standard awaits final definition.

At the Same Time, the Swiss Central Bank’s “Singleness of Money” Warning

On the very day Treasury published its rule (September 30), Swiss National Bank Governing Board member Petra Tschudin issued a different kind of warning at an event in Zurich: large stablecoins that operate outside the existing two-tier financial system could make it “harder for central banks to fulfil their mandate.” She made clear that “modernising the payment system is sensible,” but pointed to two technical transmission risks — financial disintermediation and the “singleness of money.”

The first risk is financial disintermediation. If households and businesses shift large sums from commercial bank deposits into stablecoins, banks end up with a smaller funding base and, as a direct result, reduced capacity to lend to the real economy. The central bank’s ability to influence how much credit is available, and at what cost, feeds directly into the overall effectiveness of monetary policy. This is not a concern invented for the occasion. As early as July 2026, the SNB’s financial stability report flagged disintermediation as one of the primary risks associated with stablecoin proliferation. The second risk is the “singleness of money”: because stablecoins operate outside the central banking system, a “stablecoin franc” is not automatically guaranteed to hold the same value as a real franc at every moment, and that gap directly undermines the uniformity principle.

Tschudin’s position is not a rejection of innovation. She acknowledged that stablecoins can help multinational companies move money across borders at lower cost and stated plainly that “there’s a competition between commercial banks and stablecoins” and that “competition, rivalry is a good thing, it brings innovation.” What she called for is a regulatory framework capable of preserving central bank influence, not a ban. Notably, the SNB itself is a pioneer in wholesale central bank digital currency (wCBDC), having begun issuing blockchain-based interbank digital currency three years ago and planning to continue the project until at least 2028. But Tschudin conceded that volumes on the platform remain limited and that “the big lift-off hasn’t happened yet.” The warning is not isolated. The European Central Bank, the New York Fed, and the Bank for International Settlements (BIS) have all voiced similar concerns in recent months that stablecoins could substitute for bank deposits, alter how credit institutions fund themselves, and complicate monetary policy transmission — echoing the fear behind the ECB’s proposal to revise MiCA’s stablecoin reserve rules over the direct channel between issuers and commercial banks.

Key Takeaways for Practitioners