The GENIUS Act — the Guiding and Establishing National Innovation for US Stablecoins Act — was signed into law on July 18, 2025. Its implementing rules, developed over the subsequent year through FinCEN-OFAC public comment periods and OCC rulemaking, take full effect on July 18, 2026. Two weeks from today, every US bank with $5 million in excess capital has the legal authority to issue a federally licensed payment stablecoin.
The question is no longer whether bank stablecoins are coming. The question is what happens when they arrive — and what that means for the RWA sector specifically.
What the GENIUS Act Actually Requires
The framework is straightforward. Payment stablecoin issuers must maintain 1:1 reserves in cash, FDIC-insured deposits, or short-term US Treasuries. Issuers with more than $10 billion in circulation fall under OCC oversight; those below $10 billion answer to state regulators. The OCC has published new weekly and quarterly reporting forms for supervised issuers, making the compliance infrastructure concrete. Stablecoins are carved entirely out of SEC and CFTC jurisdiction — they are payment instruments, not securities.
One important constraint: the GENIUS Act bans stablecoin issuers from paying direct yield to holders. Tether earns yield on its Treasury reserve and keeps it. Under the GENIUS Act, that model is prohibited for licensed issuers — the reserve yield stays with the issuer, not the holder. This creates an interesting structural tension: yield-bearing alternatives like USDY (which routes Treasury yield to holders through a different legal structure) are not technically payment stablecoins under the Act and occupy a separate regulatory category.
The Banks That Are Moving
JPMorgan — already operating Kinexys, a permissioned deposit token for institutional corporate payments since 2019. In early 2026, JPMorgan moved dollar tokens onto Coinbase's Base network, becoming the first major US bank to operate on a public blockchain. The bank is also exploring broader stablecoin issuance. CEO Jamie Dimon, historically a crypto skeptic, confirmed on an earnings call: "We're going to be involved in both JPMorgan deposit coins and stablecoins to understand it, to be good at it."
Bank of America — CEO Brian Moynihan left no ambiguity: "If they make that legal, we will go into that business." The GENIUS Act made it legal. Bank of America also issued a warning that reveals the scale: up to $6 trillion in deposits — roughly a third of all US commercial bank deposits — could eventually shift to stablecoins if regulators permit yield payments on them. That figure is less a prediction than a statement of the structural forces at play.
Societe Generale — The French bank's digital asset subsidiary SG-FORGE is launching USD CoinVertible, a publicly tradable dollar-backed stablecoin, on Ethereum and Solana this month. SG-FORGE previously issued a euro stablecoin in 2023 with limited adoption; the dollar version targets institutional trading and settlement use cases with a significantly larger addressable market.
JPMorgan, Citigroup, Bank of America, and Wells Fargo have been in discussions about a joint stablecoin venture, according to the Wall Street Journal. Wells Fargo has separately piloted Wells Fargo Digital Cash for internal cross-border settlement on R3's Corda blockchain. The joint venture, if it materializes, would represent a combined entity with more customer assets than any existing stablecoin issuer.
What This Means for RWA
The connection between bank stablecoins and the RWA sector is the settlement layer. Every tokenized asset — a Treasury bill, a real estate fund, a private credit product, a tokenized equity — ultimately settles in something. Today, that something is primarily USDT, USDC, or native tokens like USDY. When JPMorgan, Bank of America, and Citigroup issue their own stablecoins, they create a new category of settlement asset: institutional-grade digital dollars backed by systemically important financial institutions with explicit federal regulation.
For tokenized securities specifically, settlement in a bank-issued stablecoin looks substantially different from settlement in USDT from a compliance perspective. An institution that cannot hold USDT in its treasury can likely hold a JPMorgan-issued stablecoin. That shift in the settlement layer unlocks institutional capital that currently cannot participate in on-chain markets because no compliant dollar settlement mechanism exists for them.
The Tether Question
The arriving regulatory framework puts pressure on non-compliant offshore issuers. Tether holds roughly $184 billion in circulation and is not registered under the GENIUS Act. Starting July 18, the OCC and FDIC have formal rule authority over stablecoin issuers serving US markets — and non-compliant issuers operating in US markets face enforcement risk by approximately September 2026 (roughly 120 days post-implementation). CoinDesk's reporting notes that experts describe the GENIUS Act's exemptive approach as less robust than a full-fledged rule — the enforcement mechanism is real but the timeline is not immediate.
Tether has not announced plans to become a GENIUS Act-compliant issuer. Circle's USDC is positioned to meet compliance requirements. The competitive dynamics between compliant and non-compliant issuers will define the stablecoin market for the next twelve months.
→ Stablecoins and RWA: The Settlement Layer Explained
→ America's Tokenized Finance Infrastructure — July 4th Special
→ RWA Mainstream Adoption: What Needs to Happen