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Understanding the GENIUS Bill of 2025...

We now have some basic rules of the road for digital asset stablecoins. As expected, the primary provision is who is authorized to issue stablecoins. The GENIUS bill in large part outlines the regulatory framework for who is allowed to issue stablecoins, how authorized entities can apply for authority to issue, continuing compliance requirements, and penalties for non-compliance for authorized and unauthorized stablecoin issuers. 

Key Provisions

  • Permitted payment stablecoin issuer 
    • This is an insured depository institution, it's subsidiary, or 
    • A Federally or State qualified nonbank payment stablecoin issuer. 
  • Substantially similar state regulatory regime required
    • States must adopt a regulatory regime substantially similar to the federal regime. 
    • Threshold of $10 billion for automatic Federal oversight. 

 

Accounting Specific

There is a provision that each month issuer's must have " the information disclosed in the previous month end report examined by a registered public accounting firm." 

A standard examination engagement, as defined by the AICPA's Statements on Standards for Attestation Engagements, is a type of attestation engagement where a practitioner obtains reasonable assurance about whether the subject matter is presented fairly, in all material respects, in accordance with the applicable criteria. This is achieved by performing procedures to gather sufficient appropriate evidence to express a positive opinion in a written report. It's similar to an audit in that it provides a high level of assurance, but it focuses on subject matter other than historical financial statements.

This could be a heavy lift for monthly compliance. This compliance cost could be significant for large organizations. 

Texas Governor signs bill adding Bitcoin to States reserve assets. 

Texas becomes the first US state to commit public funds to a standalone Bitcoin reserve, aiming to treat BTC as a long-term strategic asset.

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