The GENIUS Act Is Here — What Changes for Stablecoins? w/ Jonathan Gould, U.S. Comptroller of the Currency

Ash Bennington sits down with Jonathan Gould, U. S. Comptroller of the Currency, to break down the OCC’s final rule implementing its portion of the GENIUS Act. Gould explains how the new federal framework will regulate payment stablecoin issuers, including reserve requirements, redemption liquidity, supervision, and the application process beginning January 18. They also discuss stablecoin rewards and yield, cross-border payments, U. S. dollar dominance, and why the administration sees digital assets as an opportunity to modernize the American financial system. 🏆 The Real Vision Trading is now open! The best trade ideas on the platform compete for $80,000 in cash. 📈 Trading League: https://realvision.com/your-future Timestamps: 00:00 - The GENIUS Act Final Rule 01:09 - Stablecoin Applications Begin January 18 02:20 - How the New Framework Will Work 04:01 - Stablecoins and U. S. Competitiveness 05:32 - Reserve Requirements Explained 06:56 - Why Liquidity Matters 09:10 - Balancing Innovation and Regulation 10:41 - How Stablecoin Supervision Will Work 12:18 - Reporting and Oversight 14:37 - Yield vs. Rewards 17:56 - U. S. vs. Foreign Stablecoin Issuers 19:07 - Stablecoins and Dollar Dominance 20:49 - Why Washington Sees Crypto Differently 21:42 - What Comes Next Learn more about your ad choices. Visit podcastchoices.com/adchoices

• 0:12Speaker 00

  I'm Ash Bennington on the floor of the New York Stock Exchange with Jonathan Gould, Controller of the Currency. Welcome. Thank you. Major news today from OCC, the shop that you run, rulemaking around the Genius Act. This has been a significant piece of rulemaking that lots of people in the industry have been waiting for. Tell us about the news this morning. So about, actually, over a year ago, when I, it was actually my first week when I started, President Trump signed the Genius Act into law, and I had the opportunity and privilege to attend the signing ceremony for that kind of monumental event. And that is about bringing innovation back to this country, onshoring it, and in particular, creating a federal

• 0:53Speaker 00

  framework around payment stable coins. So today, this morning, actually, our team at the OCC, which has been working on this for these last 15 or so months, released the final rule implementing the Genius Act, or at least our part under the rule. There's still a piece around Bank Secrecy Act and anti-money laundering that we're doing together with the main Treasury Department, but we got that out today. That sets us up so that on January 18th, when the law goes into effect under the statute, we will be able to start accepting applications for payment stable coin issuers. I want to talk about the details in just a second, but you've been very passionate about modernization, about technology, about innovation in this space. Tell us what this means for the United States today. So as President Trump and Treasury Secretary Besen have articulated better than

• 1:38Speaker 00

  I ever could, this is about onshoring innovation. This is about 21st century and America leading the world in this area, which is very important, digital assets. And so that is what we're trying to do. That is what Congress has done in the Genius Act. And for us at the OCC, it's also very important, you know, under President Trump and Secretary Besen's leadership, we have been focused on welcoming these activities that are financial intermediation into the banking system, whether we're talking about using blockchain technology or here today talking about payment stable coin issuance. Yeah, so I want to talk about some of the details. I think there were a lot of champagne corks in the crypto space in July of 2025, when the Act passed through Congress, but the devil's in the details. There are a lot of details to be sorted out in terms of the

• 2:19Speaker 00

  implementation, in terms of how the traditional financial services, architecture and infrastructure is going to interface with this. Let's talk about some of these points because there's new news here this morning. Sure. So, you know, obviously, this is a nascent industry. So what we've put out on the regulatory side is just one piece of the larger equation. We are also have been working behind the scenes to build a supervisory framework to put all this into place. We have benefited tremendously from the comments we received from the industry, from traditional finance players, from academics, from the whole kind of interested stakeholder universe. And I think that's resulted in a better final rule, which addresses a number of the questions

• 3:02Speaker 00

  that, you know, were raised during the proposal, but does not in any way mean that we're done with our work in the sense that, you know, as we open for business on January 18th of next year, we will have an opportunity to see all the different market structures that are developing or that are proposed and the business plans before us and the applications. From that, we will take a hard look at our, at our rules and our supervisory framework, and we will make changes as needed, if needed. So that is kind of our attitude around the rulemaking process. But again, you know, Congress has put this in place under President Trump's leadership and Secretary Besen's direction. And what we are doing is welcoming this stuff into a regulated framework for the first time. It is of monumental importance

• 3:45Speaker 00

  in terms of ensuring American leadership in this area going forward. Yeah. So you mentioned this idea of American leadership, the idea of modernizing the financial services infrastructure in the United States. Where do you think this might lead us in terms of some of the advantages, the competitive advantages that the United States can enjoy potentially over the next one, three, five years as we look forward into the 21st century, this digital infrastructure that's being built right now? Well, look, I mean, that's up to, up to all of us in the industry who are working to implement it, as well as those who are going to take advantage of it, the customers who may or may not choose to take advantage of the opportunities afforded by payment stable coins. You know, it's our job as regulators really just to welcome this innovation into the banking system. It is part of the business of banking, as I've said on multiple occasions,

• 4:28Speaker 00

  as Congress has endorsed and set the framework for. So I think there's really a lot of opportunities for us to continue to kind of push it forward. You know, I believe it will deliver a kind of faster speed, particularly in areas like cross-border payments. So I think we will see kind of hopefully over the short to medium term, real benefits to customers. And importantly, and I don't think this is at all lost on the Treasury Secretary, who, as you know, is an economic historian and a student of all this. You know, this is very important when we talk about US dollar dominance over the, over the future. So payment stable coins are a mechanism for growing that, ensuring that, that is important, not just obviously to the US, but even beyond.

• 5:12Speaker 00

  Yeah, and it creates demand, of course, for US Treasury securities. Absolutely. Yeah. Let's talk about some of those details there specifically. And you pointed out that this is something that's still very much a work in progress as this process unfolds. This is totally new, something we've never seen before. So there are going to be some questions about this. One of the things that you address in that very long 700-plus-page document that dropped this morning that I was skimming through before this interview was the idea of what's going to happen with the reserve requirements. Some rulemaking has been set forth in that document. Talk a little bit about how these assets will be reserved. This has been a major question, particularly in the, in the Wild West days before the regulation began to embrace this. Talk a little bit about the reserve requirements, why it's important, why it matters, and how it's going to be implemented.

• 5:54Speaker 00

  So, so the reserve requirements are, are one of the kind of core foundations of the regulation, and it goes to what it means to be a stable coin, emphasis on the word "stable." And so this is really kind of taking us back to an earlier part of our history at the OCC. You know, we were originally created back in 1863, and our job then was to ensure that bank-issued notes had the actual value and were backed by assets commensurate with the value that was on the face of the note. So what Congress has asked us and directed us to do is very similar in analogous to what we were doing back in the 1860s in our kind of initial iteration. So it's very exciting for the industry. Congress laid out specifically

• 6:38Speaker 00

  in statute a number of assets that could constitute reserves for, for a stable coin. And so obviously, we've been faithful to the statutory mandate, but provided a lot more details around that with a real focus on managing liquidity risk and making sure that those assets will be there to back those stable coins. Talk a little bit about liquidity risk and why it's so important in understanding how this implementation will move forward. Well, I mean, you know, from the customer's perspective, and I think from the congressional perspective, you know, again, the emphasis on making sure we have a digital asset that is stable in value and having the ability to redeem it, right? And so, you know, if as a customer I want to redeem my stable coin, you know, we need to make sure there

• 7:21Speaker 00

  is a regulatory and supervisory regime in place to ensure that if a customer comes and says, "Hey, I want to redeem this stable coin," that there are assets that can be liquidated in the short term to make sure they're meeting the redemption requests or the volume of redemption requests. So that is something that we were primarily focused on because that is one of the core kind of tenants of stable coin and what our regulation is designed to address. So we put a lot of focus on that. And again, benefited tremendously from the engagement with, you know, all the comment letters we got, hearing from bankers, hearing from digital asset companies and beyond. Yeah, that was part of the reason why this process took so long, is you had those requests for proposal, requests for comments from the private sector. So you could hear

• 8:05Speaker 00

  from those companies that are actually going to be implementing this technology, putting it into the architecture of the banking system. That's, that's exactly right. And I will say, we still have a lot of learning to do, right? I mean, it is always the case that when we're talking about designing a regulatory and supervisory framework, we should periodically reassess to make sure it's still fit for purpose, make sure it's not having unintended consequences. That's particularly true where, as here, we're talking about a nascent industry. We want to make sure that we're providing, I think as Congress intended, as the President intended, as the Treasury Secretary intended, to have a framework that is supportive and welcoming. So we will, of course, evaluate and continually reevaluate whether or not our regulatory and supervisory framework,

• 8:48Speaker 00

  part of which we announced today, at least the regulatory side, continues to be fit for purpose, particularly as we open for business on January 18th and start seeing the range of applications with the range of business plans, market structures, et cetera, before us. Not a lot of time. Well, not a lot of time, but I mean, we did get a head start. You know, the legal and other team at the OCC, which did a tremendous job on all this, they were working even before the President signed it into law, had already started getting a running start on this because we knew it would be a mammoth undertaking. It's a very delicate balancing act on the regulatory side because you have to provide enough information to provide clarity, but not so much that you over-regulate and overstructure. Talk a little bit about that balancing act and the commentary and discourse that you had with some of the people in the private sector who reached out for during

• 9:33Speaker 00

  that comment period. Right. So we obviously had a Robust comment period and got a lot of comments and benefited tremendously from that. But, you know, I take comfort in the fact that whatever we put in place, what we put in place today should not be fixed in stone, meaning that if we see that we have done something that doesn't make sense, or we need to make a tweak, we will do so. You know, I think you should always expect, and I think the industry and the American public should expect, that its regulators will periodically reassess and revise if things don't make sense. And so, you know, please don't think this is written in stone and not going to change. But yes, we, you know, we attempted to do a balancing act. We recognize Congress has asked us to, to design a regulatory framework around something

• 10:17Speaker 00

  that is still in its infancy, right? And, you know, I can't entirely predict the future. I'm not aware anyone who can predict the future. You know, I've seen a lot of folks and studies attempting to predict the future. I treat them with a certain degree of skepticism, as I think, you know, is to be expected. And so, we have done something that we think is entirely consistent with the statute. And now, we're really focused on the supervisory side too, making sure that piece of the equation, which is less visible to the public, is in place and ready to go on January 18. So, talk a little bit about the supervisory component. I think you guys have 90 trillion or so in assets under supervision, an absolutely massive portfolio, something like 2/3 of the commercial banks in the United States, regulated by OCC.

• 10:59Speaker 00

  Talk about what the supervisory component of this is and how that will play out after January. Right. So, one thing I think sometimes people think is that, well, you know, the rule is everything. Well, the regulation is obviously extremely important, but when you think about how a rule is applied to a supervised entity, right? Supervision is a process of taking an abstract principle in regulation and applying it to the idiosyncratic facts on the ground, in this case, or in our case, of a federal qualified payment stablecoin issuer. So, that requires judgment, that requires, you know, discretion. And so, what we are trying to do, again, is to design a framework, make sure that we

• 11:40Speaker 00

  are applying those regulations in a consistent manner across kind of all our ultimately licensed payment stablecoin issuers, so that they can expect a certain degree of transparency from us, and the public can have a certain degree of transparency around our supervision activities here. And ultimately, that is fundamentally about driving public confidence that these are, in fact, stable coins, emphasis on stable, right? And so, our regulatory and supervisory framework, which complements and implements our regulatory framework, it's all about driving that public trust ultimately in these, in this form of digital asset, namely, stablecoins. Yeah, so the supervisory component is all about the daily, day-to-day questions that are going to come up as this ongoing operation goes forward with real entities on the ground. That's right.

• 12:25Speaker 00

  And you'll notice today, although obviously much of the news is focused on the 700-plus page, final rule, but there's a lot more out there that we released already, including reporting forms, you know, weekly and monthly, that licensed issuers are going to have to provide to us, which will help us understand what's going on and to monitor their activities so that we can do our job as a safety and soundness regulator and make sure that those, importantly, those reserves are actually available and on hand to back redemption requests, for example. So, there's a lot more coming out, as well as a rating system, where we will evaluate, you know, similar, but not identical to how we think about banks, with the so-called Camel's Rating System. We have an analogous component, or a rating system for our, for our payment stablecoin issuers.

• 13:10Speaker 00

  So, again, you know, we're creating this out of whole cloth, but not without experience. We have 163 years of supervisory experience in this place, in this space, excuse me. And I have a lot of confidence in the team. They've been working, you know, with a lot of dedication and focus. We've been accessing, again, you know, folks, industry players, others who understand these areas, to make sure that we're getting the best possible learning. We've been working with other agencies, not just on the federal side, but beyond, to make sure we're, again, getting the benefit of their experience too. And again, this, this brings us back to what we were at our outset, back in 1863 in the National Currency Act. So, it was a very exciting time for us. And, you know, this is something that we've been doing in one way or another for 163 years.

• 13:53Speaker 00

  So, that, that's a message I want to make sure that, you know, your, your viewers hear and understand, that, that we are not coming at this fresh. Yes, this is a nascent industry, but we have a lot of experience managing the risks that are associated with stablecoin issuers, and I have full confidence in our team to do it. Founded by Abraham Lincoln. I mean, that's pretty extraordinary. That, that is. 1863 National Currency Act, Abraham Lincoln, and then Treasury Secretary Sam and P. Chase, you know, put this scheme together to, you know, to grow nationwide banking markets, to knit together the, the political union that they were literally defending on the battlefield. So, today, of course, we have President Trump, we've got Secretary Besen, a student of economic history himself, you know, getting together again, you know, with the Genius Act to put this in place.

• 14:36Speaker 00

  It's, it's, it's all together right and appropriate that, that the OCC, the Bureau of Treasury, play a central role going forward. I want to talk about some of the open questions that have been debated back and forth, particularly the idea of yield versus rewards. The Genius Act specifically prohibits yield-bearing stablecoins, but this, the question about ongoing rewards, the question of whether or not third parties can pay the rewards, this is something that has been a much debated topic. Talk a little bit about this and where the rulemaking comes down. So, happy to talk about that. So, obviously, in the proposal, we came up with this rebuttable presumption concept, which was designed just to kind of test things out. You know, you mentioned earlier about, you know, you want to provide enough detail, but you want to constrain things.

• 15:18Speaker 00

  So, we wanted to see what people would say if we attempted to implement the anti-invasion, evasion requirement through this rebuttable presumption. You know, what, what I learned from the comments, again, and, you know, hearing from, from, I met with over, for example, 1,000 community bankers over the last year and heard a lot from the comment letters, so learned a tremendous amount, as did, I think, all of us at the OCC, is that it would be premature to start drawing lines in the sand now as to what, what relationships with third parties or what relationships with affiliates are kind of ex-ante prohibited. In contrast, I feel a lot more comfortable on January 18th, when we get actual applications in hand with business plans laid out before us.

• 16:02Speaker 00

  And I anticipate we'll get scores of applications coming in right off the bat. We will then have more than just anecdotal knowledge of how a certain market might be structured. We will see concretely, this is what the universe looks like, at least out the gate. And that will allow me and the rest of the team at OCC to make more informed decisions about, hey, you know, this looks problematic and inconsistent with what Congress wanted in its prohibition on yield or rewards, whereas this looks okay. But based solely on anecdotal information or comment letters, I didn't think we had enough information to hardwire things in a final rule, particularly whereas here, we're talking about a nascent industry.

• 16:43Speaker 00

  And so, I wanted more time for us to develop a more informed view as to whether or not it would be appropriate to draw lines in the sand on that and say, hey, you know, ex-ante, this type of relationship is evasive and therefore prohibited. So, you'll see what we did in the final rule is we revert it to the actual language in the statute itself. And that sounds like it harkens back to this division between regulatory versus supervisory, not trying to create a, a sort of a platonic template that can be applied ex-ante to these things, but looking at what actually comes down the pike and advising on the specific circumstances, the specific plans of the institutions that you supervise. That, that's exactly right. And again, this is something that we have experience with doing, and, you know, it

• 17:26Speaker 00

  gives us, particularly in areas where they are either new or they are new to us, it gives us more time to reach informed conclusions, rather than just rushing in and potentially kind of hamstringing, you know, the desire of Congress to actually onshore innovation in the form of a payment stablecoin federal framework. So, we wanted to be thoughtful about it. It doesn't mean that we're not going to honor the statute. Of course, we're going to honor the statute. We're going to look at it case-by-case basis, but if we're going to draw blanket lines in the sand, I want more information, and I want to see how the industry evolves over time. Another question that's been raised is this idea of US versus non-US stablecoin issuers. How do you think about balancing out, creating an open financial system, but also making

• 18:11Speaker 00

  certain that that benefits the United States? Well, look, I mean, some of these questions, you know, are of geopolitical significance, you know, questions around US dollar dominance, things of that nature. You know, Congress recognized that, and that's why they empower the Treasury Secretary to play a really important role in that, in terms of, you know, negotiating some of the reciprocity arrangements with, with non-US jurisdictions. Obviously, those are going to be of central importance to making sure that we have multi-jurisdictional issuers, to, to make sure that we can actually get the, the benefit of what I think Congress intended, including using payment stablecoins to facilitate both in speed and reduce costs cross-border payments.

• 18:56Speaker 00

  So, you know, as befits the Bureau of Treasury, we have been working extremely closely to support the Treasury Secretary and the excellent work that they all are doing at the main Treasury Department, to make sure that everything we're doing in our rule is in lockstep and is reinforcing these, you know, broader geopolitical goals. Yeah, I've had the pleasure of interviewing Secretary Besen right here on Real Vision, and I also was able to hear him speak at the Economic Club of New York a number of months ago, where he delivered that very passionate speech about ensuring American global competitiveness. How does this relate to that? You've touched on some of the points there, but I'm curious about how you think about how stablecoins can drive US global competitiveness. Well, look, I mean, as, as others have talked about, I'm sure more eloquently than

• 19:39Speaker 00

  I, it's very important that, you know, the, the US dollar remain the reserve currency for the world and that it remain kind of a stable and valued by not just American citizens, but by a whole host of others. In fact, you know, an entire kind of market infrastructure has been built around it. And so, I think what we are doing, what Congress has done, again, under President Trump and Secretary Besen's leadership, is create a mechanism through payment stablecoins where we can reinforce that and export it even further. And of course, this all inures the benefit of the customers ultimately who are using payment stablecoins and, you know, getting faster and cheaper payments than they might otherwise.

• 20:23Speaker 00

  So, you know, this is bringing us into the 21st century. Obviously, the US payment system has, in some cases, not been optimal over the vast, you know, over, over the last few decades. Right. So, this is really an upgrade too, to the payments infrastructure of this country in a way that is entirely consistent with Larger kind of strategic objectives across the executive branch. It's really interesting to hear you and the rest of the administration talking about this as an opportunity rather than as a risk, which it seemed in prior years we had perhaps heard. Well, look, I mean, you know, as you know, as someone who's been in this space for a decade, there are a lot of benefits, including not just around speed and efficiency, but also around transparency. Yeah.

• 21:08Speaker 00

  And and and kind of auditability, you know, the ability to like track global payments. That that has implications even on kind of the Bank Secrecy Act anti-money laundering side too. Right. Where, you know, we expect banks and other financial institutions that we and other federal banking agencies supervise to know their customer, to essentially be eyes and ears for our law enforcement across the country. And so payment stablecoins, you know, given its transparency, given just the very nature of it and the kind of the auditability of it is extremely valuable in that regard as well as a tool of US government policy. Controllers, we come to the conclusion of this conversation.

• 21:53Speaker 00

  Finally, what do you hope people in the cryptocurrency digital asset space take away from today's rulemaking activity? Look, I think people should be excited. People should recognize that this is, this reflects the hard work of a lot of people, not just the OCC. There are, you know, a number of folks who who deserve credit, first and foremost, obviously, President Trump, Secretary Besen, and driving this home and getting this across the finish line. But but the work's not done here, and I would just note too that we were just at the beginning. And, you know, a lot of folks talk about, you know, digital assets or crypto versus traditional banking. I'm here to reiterate, all of these things are just aspects of financial intermediation. This is the business of banking.

• 22:37Speaker 00

  The business of banking is not boring. It is dynamic. It has evolved over time. Just in our 163 year history, it has changed dramatically. But it is about serving a purpose. And and, you know, that is what the Genius Act enables. And so we're very excited to be a part of that. But the work is not done. There's lots more to do still. Controller Ghul, thank you so much for joining us. Thank you for having me.

• 23:01Speaker 01

  You obviously enjoyed the episode because you're here with me at the end. But listen, don't forget to go to realvision.com/join and grab a free membership. It's an incredible community packed with alpha, great investment ideas, and the research that you need to help you unfuck your future. So get started now. Go to realvision.com/join.