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| MARKETS — FUTURES — as of Sep 25, 6:34 AM ET |
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Friday, September 25 · Lead Federal Reserve proposes stablecoin rulebook for state member banks The Federal Reserve became the last of the four banking agencies to put a stablecoin rulebook on the table, proposing Thursday how a state member bank or its subsidiary may issue a payment stablecoin under the GENIUS Act. One proposal sets reserve, capital, risk-management and safekeeping standards. The other builds the application process, with business plans, financial disclosure, plus procedures for appeals and hearings. Comments close 60 days after Federal Register publication, which had not occurred as of Friday. Better Markets says the package leaves financial-stability risks unaddressed. No firm holds an issuer license today.
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10-day trend Sep 25, 6:00 AM ET
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| ▸ | What the Board actually proposed — Reserves must fully back outstanding coins in permissible assets — short-term Treasury bills and other high-quality liquid assets — with capital standards calibrated to credit and operational risk rather than borrowed wholesale from the bank capital rules, plus safekeeping requirements for the backing assets themselves; the Board also states plainly that stablecoin issuance is a permissible activity for the banks it supervises, which is the sentence bank counsel will cite first. Coverage of the text describes a two-business-day redemption standard and tiered capital charges, matching the outer limits the OCC, FDIC and NCUA each proposed earlier. The Fed proposal remains the only one covering state member banks. |
| ▸ | The supervisory gap closes; the clock does not — Every primary federal stablecoin regulator now has a proposal out, and none has a final rule. The statute takes effect on the earlier of January 18, 2027 or 120 days after the first final rules issue, which means a November finalization at the OCC — Comptroller Jonathan Gould's stated target — would start a 120-day clock that runs past January 18, leaving the statutory date as the binding one. A bank that wants to issue through a subsidiary should be drafting the application against a rule it can still shape. The application process is itself a proposal. |
| ▸ | The comment strategy that matters — The Board is asking two different questions in two documents, with different owners for the answers. Treasury and finance own the reserve and capital design. Corporate and legal own an application process that sets what a business plan must contain before a single coin is minted. Institutions that filed on the OCC's part 15 proposal in the spring should check whether the Fed's capital calibration contradicts what they told the OCC. Inconsistent comment files become examination questions later. |
REGULATORY DEVELOPMENTS Two OFAC final rules took effect Friday, and between them they do opposite things: one tidies the penalty regime, the other removes an authorization compliance teams have been relying on. | ▸ | Syria's general license disappears: OFAC removed and reserved 31 CFR §596.505, the Syria-specific general license under the Terrorism List Governments Sanctions Regulations, effective September 25 with no transition period. The removal follows the President's rescission of Syria's State Sponsor of Terrorism designation effective August 24, 2026, itself resting on a July 8 certification that Syria had not supported international terrorism for six months; the license existed only because the designation did, so its deletion narrows a permissions pathway rather than adding a prohibition. Any institution that cited §596.505 in a transaction memo, a trade-finance approval or a correspondent policy must find another basis today. Willful violations remain criminal under 50 U.S.C. 1705. |
| ▸ | Penalty provisions consolidate into Part 505: OFAC's other final rule, also effective September 25, gathers civil and criminal penalty provisions scattered across 31 CFR Chapter V — the Trading with the Enemy Act, the UN Participation Act, the Kingpin Act and others — into a single new Part 505. Nothing substantive moves: the IEEPA civil maximum stays at the greater of $377,700 or twice the transaction value, base penalties are still halved for voluntary self-disclosure, and OFAC still weighs willfulness, recklessness and harm to sanctions objectives. What changes is the citation in your policy manual and your training deck. Update the cross-references before the next exam. |
| ▸ | A prohibition order for a teller: The Federal Reserve on September 24 issued a consent prohibition against Renee Nicole Brown, a former Sandy Spring Bank employee, following her guilty plea to embezzling roughly $246,000 from teller cash dispensers over the course of a year. The action reaches the individual, not the bank. What it documents is a control gap that ran twelve months before detection — dispenser reconciliation is the specific line item worth pulling. |
| ▸ | CFTC refreshes its crypto FAQs: Commission staff updated its frequently asked questions covering registrant and registered-entity activity in crypto assets and blockchain technology. Bank-affiliated futures commission merchants and swap dealers with digital-asset desks should diff the new answers against the old ones; staff FAQs are not rules, but they are what an examiner reads first. |
INDUSTRY AND AI SIGNALS | ▸ | The 10-year at 5.162 percent — The benchmark yield rose about 5 basis points in pre-market trading Friday, extending a move that has taken it up about 15 basis points since last Friday's close. Freddie Mac's 30-year mortgage rate printed 7.03 percent this week, its first reading above 7 percent since January 2025. Crude fell about 2 percent to near $92.71 a barrel. |
| ▸ | The Clearing House picks a tokenized-deposit vendor — TCH selected Quant to power the On-Chain Money Initiative it announced in June, a network intended to let US institutions of every size clear and settle tokenized deposit transactions. This is the deposit door rather than the issuer door: a tokenized deposit pays interest, keeps insurance and needs no GENIUS approval that does not yet exist. IBM separately connected its Digital Asset Haven platform to Swift's shared-ledger beta, and Swift and Wells Fargo both joined the Linux Foundation Decentralized Trust. The plumbing is being built by incumbents. |
| ▸ | Buy-now-pay-later becomes an underwriting blind spot — Sixteen percent of consumers took a BNPL loan in 2025, per Federal Reserve data, with growth concentrated among lower-income borrowers using the product for groceries and other routine spending. Those obligations largely do not appear in the credit files banks underwrite against, which means a consumer book can be carrying leverage it cannot see. Credit-risk teams should ask their bureau vendors what BNPL coverage they actually receive. |
| ▸ | An approval and a risk chief — The Federal Reserve approved Santander's acquisition of Webster Financial, per reporting on the decision. Separately, Wells Fargo named Chief Operating Officer Scott Powell as its next chief risk officer; Derek Flowers retires in mid-January. Powell was hired by CEO Charlie Scharf to work through the bank's regulatory problems. |
POLITICAL & LEGISLATIVE | ▸ | Warren revives the private-equity bill: Senate Banking Committee ranking member Elizabeth Warren and other Democrats reintroduced legislation that would tie private equity firms to the debt of their portfolio companies. It arrives as the Committee on Capital Markets Regulation publishes a study on private credit and bank interconnectedness, a subject examiners have been asking about in subscription-line and fund-finance books. The bill faces a Republican Senate; the exposure question outlives it. |
| ▸ | A CFPB appropriations bill: The House Financial Services Committee approved legislation that would place the CFPB under the congressional appropriations process. Funding structure, not any single rulemaking, is what sets how much examination capacity the bureau can field. Consumer-compliance teams planning 2027 supervision assumptions should treat the bureau's resourcing as an open variable. |
| ▸ | A romance-scam disclosure bill clears the Senate: The Senate passed by unanimous consent a House-passed bill requiring dating websites to warn users about romance scams, sending it toward enactment. Fraud teams at banks carry the losses these scams generate through faster-payment rails. The FTC separately said it will explore rulemaking on ad-optimization practices that feed impersonation scams. |
| ▸ | A Polymarket gambling suit: The New York attorney general sued Polymarket, accusing the platform of running an illegal gambling operation, and Senate Democrats pressed for a public hearing on prediction markets. With federal crypto market-structure legislation stalled and the rulemaking track left to the agencies, state enforcement is where the prediction-market perimeter is being drawn. Banks providing deposit accounts or payment rails to these platforms should re-read their gambling-related transaction policies against a state-law theory rather than a CFTC one. |
WHAT'S COMING | ▸ | The FDIC's reciprocal-deposit proposal under the 21st Century ROAD to Housing Act and the OCC's proposal on how it classifies violations of laws or regulations both close next Thursday. Community banks funding large balances through reciprocal networks should file deposit arithmetic that reflects a 5.16 percent 10-year, not spring's forecast. |
| ▸ | Federal Reserve notices on permissible nonbanking activities and changes in bank control publish today; the control notice is where new acquirer filings first become public. |
WHAT IT MEANS | ▸ | The Fed's proposal completes the rulebook, which means the binding constraint on bank stablecoin issuance is no longer regulatory uncertainty — it is the calendar. The statute's effective date is January 18, 2027 unless a final rule lands early enough to beat it: the OCC targeting November would start a 120-day clock ending after that date, so January 18 binds, and the Board's application process would need to be final and operating by then for a state member bank to get through it. A bank that intends to issue has two things to do inside the comment window, and they are not the same document. File on the capital and reserve design, where the numbers are still movable. File on the application content, where the cost of a badly specified business-plan requirement is measured in months of processing. The institutions already settling card volume in tokens they issue did it without any of this, through the deposit door and the trust-charter door. The Board's proposals are the price of the third door. |
Dates That Matter SEP 25 today | Comments close: Swap Execution Facility Order Book Requirement for Permitted Transactions [CFTC] | SEP 25 today | Watch: comments due on the OCC information collection for PPSI licensing applications [Watch] | SEP 28 3d | Watch: Supreme Court conference on Nos. 25-1313, 25-1350, 25-1004; order list expected Oct 5, 2026 [Watch] | OCT 1 6d | Comments close: Violations of Laws or Regulations [OCC] · Reciprocal Deposits: Implementing the 21st Century ROAD to Housing Act [FDIC] · Privacy Act Regulations [CFTC] · Special measure: Banque Misr UAE [FinCEN] | OCT 1 6d | Effective: Telemarketing Sales Rule Fees [FTC] |
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