The Federal Deposit Insurance Corp.’s (FDIC) April 7, 2026, proposed rulemaking tied to the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act includes a comprehensive set of accounting and auditing requirements for permitted payment stablecoin issuers (PPSIs).
The GENIUS Act, enacted in July 2025, is the first national set of rules for stablecoins—digital currencies designed to keep a fixed value, usually equal to $1.
The proposal, issued as RIN 3064-AG19, would create a reporting and control framework for PPSIs. The rule would implement statutory requirements applicable to FDIC-supervised issuers and certain custodians.
US GAAP Reporting Framework
Under the proposal, PPSIs are required to prepare certain financial information that complies with U.S. GAAP.
For reserve accounting, reserve assets backing outstanding payment stablecoins would be valued at fair value, except for U.S. coins and currency, which would be valued at face value.
The FDIC said it expects reserve assets to be recorded on the PPSI’s balance sheet under U.S. GAAP and included in quarterly reports required under the proposal and in Call Reports for the parent insured depository institution.
Monthly Reserve Reporting
The proposal would require monthly public reserve reporting. A PPSI would have to prepare a report showing as of the close of business on the last day of the prior month the total number of outstanding payment stablecoins and the value and composition of reserve assets.
The template included in the proposal lists deposits, insured and uninsured deposits, Treasury bills, notes or bonds, money received under repurchase agreements, reverse repurchase agreements, securities issued by an investment company solely invested in qualifying reserve assets, reserves in tokenized form, total reserve assets, outstanding repurchase agreement liabilities, and total reserve assets net of outstanding repurchase agreement liabilities.
Monthly Exam by Accounting Firms, Executive Certifications
The proposal also would require a monthly examination of the reserve composition report by a public accounting firm.
The accounting firm would issue a written report with findings to the PPSI’s audit committee or to the board of directors if there is no audit committee.
In addition, the chief executive officer and chief financial officer of a PPSI would be required each month to submit to the FDIC a certification as to the accuracy of the previous month-end report, including a copy of the accounting firm’s written report. The certification must be truthful under criminal penalty.
This creates accountability similar to that imposed by the Sarbanes-Oxley Act of 2002 for public companies regulated by the SEC.
Ongoing Financial Reporting to FDIC
Beyond monthly reserve reporting, the proposal would require a confidential weekly report to the FDIC. Such reporting could include information regarding reserves, issuance and redemption, and other relevant information.
The proposal also would require a quarterly report of financial condition, which would be similar in concept to a bank Call Report, but in a more streamlined manner. A PPSI would have to file the quarterly report with the FDIC within 30 days of the end of the prior quarter in a standardized format prescribed by the agency.
The filing would include an income statement, balance sheet, reserves, changes in equity, investments, capital, outstanding issuance value, and assets under custody.
Each report would require the PPSI’s CFO to attest to its accuracy. Directors and senior management other than the officer making the declaration must also attest to the accuracy of the report of financial condition.
Recordkeeping and Internal Control
PPSIs would have to maintain a complete set of books and records and develop and implement a records retention policy.
The proposal sets internal control and internal audit requirements tied to financial and regulatory reporting.
A PPSI would have to maintain internal controls and information systems appropriate to its size and complexity and the nature, scope and risk of its activities. Those systems would have to provide for timely and accurate financial, operational and regulatory reporting, adequate procedures to monitor, safeguard, manage and control assets, and compliance with applicable laws and regulations.
Each PPSI also would have to maintain an internal audit system appropriate to its size and complexity and the nature, scope, and risk of its activities.
The proposed rule says that system must provide for monitoring of internal controls through an internal audit function, or for smaller or less complex issuers, a system of independent reviews of key internal controls, along with independence and objectivity, qualified personnel, adequate testing and review, documentation of tests and findings, and verification of management actions to address deficiencies.
Annual Audits for Large Issuers
For larger issuers, the proposal would add an annual financial statement audit requirement. A PPSI with more than $50 billion in total outstanding issuance value that is not already subject to the reporting requirements under Section 13(a) or 15(d) of the Securities Exchange Act of 1934 would be required to prepare annual financial statements in accordance with GAAP. The proposal says those statements must include disclosure of related-party transactions as defined by GAAP.
Those annual financial statements would have to be audited by a public accounting firm. The audit must be conducted in accordance with PCAOB auditing standards, or, for non-public entities, in accordance with GAAS or PCAOB auditing standards.
A PPSI subject to the annual audit requirement would have to make the audited financial statements publicly available on its website and submit them to the FDIC within 120 days after the end of its fiscal year.
The proposal also says the FDIC may at any time request that a registered public accounting firm provide certain additional information or documents relating to information provided by the PPSI.
Comments are due 60 days after publication in the Federal Register.
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