Will Payment Stablecoins Mean the End of State Money Transmitter Licensing?
By: Judith Rinearson, Jennifer L. Crowder, and Joshua L. Durham
The GENIUS Act (Act) allows “permitted payment stablecoin issuers”—which term includes nonbanks that are either Federal qualified payment stablecoin issuers (FQPSI) (regulated by the OCC) or State qualified payment stablecoin issuers (SQPSI) (regulated by their qualifying state)—to:
- Issue and redeem payment stablecoins;
- Manage reserves;
- Custody payment stablecoins, reserves, or private keys of payment stablecoins; and
- Engage in activities that “directly support” the above listed activities.