On 18 August 2026, the US Treasury and the Financial Accounting Standards Board each published a separate proposal on stablecoins — one on who can legally sell them, the other on how companies should book them. Both ask the same underlying question: can a holder actually redeem a stablecoin for a dollar, not just sell it on an exchange.
Two Agencies, the Same Question
Treasury's Notice of Proposed Rulemaking implements Section 3 of the GENIUS Act, the stablecoin law signed on 18 July 2025. The rule would bar exchanges, wallets, and brokers from offering a payment stablecoin to a US person unless the issuer has completed a "permitted issuer" process. It poses 43 numbered questions to the public and sets a comment deadline of 19 October 2026.
Issuer licensing takes effect 18 January 2027, while the distributor restriction doesn't fully apply until 18 July 2028. Knowing participation in unlawful issuance can carry fines up to $1 million per violation and up to five years in prison.
FASB, meanwhile, is not a regulator — it sets the accounting rules public companies use to classify assets. Its exposure draft proposes a three-part test for whether a stablecoin can count as a cash equivalent: the holder needs an on-demand contractual right to redeem with the issuer, the issuer must hold at least 1:1 reserves in segregated, liquid accounts, and secondary-market liquidity cannot substitute for that redemption right. FASB's comment window closes 19 November 2026.
Why the Redemption Test Matters
Most retail stablecoin holders exit by selling on an exchange rather than redeeming directly with the issuer, since direct redemption is typically reserved for institutional counterparties above a minimum threshold. Under FASB's proposed framework, that distinction could determine whether a company's holdings even qualify as cash equivalents on its books.
The test also puts a spotlight on reserve composition. Tether's Q2 2026 attestation, prepared by BDO, showed total reserves of $187.75 billion against roughly $184.6 billion of USDT in circulation, implying excess reserves of about $4.11 billion — down from about $8.23 billion the prior quarter. That reserve base includes roughly 146.2 tonnes of gold and about 98,933 BTC, assets that are not short-term and liquid in the way Treasury bills are.
The Timeline Ahead
According to reports, Comptroller Jonathan Gould stated at the SALT conference that the OCC intends to get a final rule out by November and start processing applications within the new year, a compressed schedule given that statutory implementing rules were already due by 18 July 2026. Neither the Treasury proposal nor the FASB draft is final, and both remain open to public comment.
Source: Live Bitcoin News
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