Research Briefs
RESEARCH BRIEFS
Published Briefs
The OCC Proposes a Yield Prohibition That Reaches Beyond the Statute
The Office of the Comptroller of the Currency has proposed a GENIUS Act rule that extends the statute's yield prohibition beyond the parties Congress chose to restrict. US-chartered issuers operating under that expanded prohibition will face constraints that foreign issuers, state-chartered alternatives, and unlicensed platforms will not.
The NCUA's First GENIUS Rulemaking Creates a One-Way Investment Gate
The NCUA's first GENIUS Act rulemaking contains an asymmetry that is easy to describe and hard to justify. Federally insured credit unions may receive unlimited outside investment under the proposed framework, but may not invest in payment stablecoin issuers supervised by a different regulator.
The GENIUS Act's 21 Rulemakings and the Race to Define the Stablecoin Market
The GENIUS Act's stablecoin framework will not be determined by what Congress wrote. It will be determined by 21 separate rulemakings from four federal agencies with different interpretive instincts and no shared enforcement mechanism for their deadline.
American Dynamism and the Distributional Question the Frame Cannot Answer
The policy debates surrounding GENIUS Act implementation are being conducted inside an ideological frame that holds American economic leadership is a function of capital mobilization velocity. The distributional question that monetary and regulatory analysis cannot avoid is absent from that frame.
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