The rules are starting to land. Some of the inputs are still missing.
That’s the message banking groups are sending as the Federal Deposit Insurance Corporation begins implementing the GENIUS Act’s stablecoin framework. The FDIC has moved first with a proposed rule outlining how banks could seek approval to issue payment stablecoins through subsidiaries.
Now, industry associations are asking for more time to respond, arguing that one piece of the framework isn’t enough to assess the whole.
The First Rule Is Out, but Not the Full Picture
In December, the FDIC issued a notice of proposed rulemaking to establish a process for FDIC-regulated institutions to apply for approval to issue payment stablecoins through a subsidiary. The proposal is part of the GENIUS Act’s broader mandate to create a federal regulatory framework for payment stablecoins.
That move made the FDIC the first agency to formally propose implementation rules under the new law.
But according to a joint letter sent this week, banking and trade associations say the proposal arrived ahead of other required rulemakings that will shape how the framework ultimately works.
Specifically, the groups point out that separate proposals covering capital, liquidity, risk management, and other prudential requirements have not yet been issued.
Why Timing Matters to Commenters
In their letter, the associations said they need more time to evaluate the FDIC’s proposal in context, particularly how it will interact with additional rules that other agencies are expected to issue under the GENIUS Act.
They noted that the law requires a coordinated set of regulations, and reviewing one component in isolation makes it harder to assess the full compliance and operational impact.
“We appreciate the FDIC’s effort to undertake this rulemaking quickly,” the letter said, adding that Congress’s policy goals can only be achieved if affected parties have the opportunity to consider all required rulemakings “holistically.”
What the Groups Are Asking For
Under the current timeline, comments on the FDIC proposal are due by February 17.
The associations are asking the FDIC to extend that deadline in one of two ways: either by 60 days, or until 30 days after the agency issues a separate proposal addressing capital, liquidity, risk management, and related requirements.
The request reflects a practical concern.
Stablecoin issuance under the GENIUS Act will sit at the intersection of multiple regulatory regimes, and commenters want to understand how those pieces fit together before offering detailed feedback.
A Process Question, Not a Policy Reversal
The letter does not challenge the GENIUS Act itself, nor does it oppose the creation of a stablecoin framework.
Instead, it focuses on how the framework is being rolled out and whether stakeholders have enough information to respond meaningfully.
That distinction matters. The FDIC has already taken a clear step toward implementation. The question now is how quickly the rest of the regulatory architecture comes into view.
What to Watch Next
The immediate decision rests with the FDIC: whether to extend the comment period or hold the current deadline.
Beyond that, attention will shift to when additional GENIUS Act–related rulemakings are released and how agencies coordinate their timelines.
For now, the signal is straightforward. Implementation is underway. The process is active. And the next phase will be about aligning the pieces so the framework functions as intended.
