Friends in the crypto circle should still remember that on July 2025, Trump signed the "GENIUS Act." Not long after, the U.S. Department of the Treasury launched an ANPRM for public comment, sparking heated discussions in the community.

I believe everyone is eager to learn about the latest developments. The Sa Sister team’s article will follow the usual format, first taking you through the history of stablecoin development in the U.S., and then breaking down the core focus of the "GENIUS Act" and the ANPRM.

Old friends know that early U.S. crypto regulation was a "multi-headed battle": the SEC said cryptocurrencies are "securities," the CFTC said they are "commodities," and the states varied widely, with New York's BitLicense being so strict that it discouraged businesses, while Wyoming rolled out the red carpet for crypto companies. In 2025, the situation began to change, with the introduction of the "GENIUS Act" and the "STABLE Act" in both the House and Senate, marking the entry of U.S. stablecoin regulation into the "Gemini" era. Therefore, if you want to understand the current state of U.S. stablecoins and the role of the public comments on the "GENIUS Act," these two pieces of legislation need to be discussed together.

These two acts can be regarded as the "Gemini" of U.S. stablecoin legislation, with similar paths.

First, let's look at the "GENIUS Act" (full name: "2025 Guidance and Establishment of a National Innovation Act for U.S. Stablecoins"), proposed by senators in February 2025, which is primarily tailored to develop a path for "payment stablecoins." Its key contents can be summarized at a glance:

Next, we examine the "STABLE Act" (full name: "2025 Stablecoin Transparency and Accountability Better Ledger Economy Act"), which shares the same core logic as the "GENIUS Act," but with some differences in detail. First, the positioning is different. While it also defines payment stablecoins, it particularly emphasizes that "issuers must commit to being able to redeem, exchange, or repurchase at a fixed currency," highlighting the capital preservation attribute; second, the core rules are the same: maintaining a 1:1 ratio of high-quality liquid assets, regular audit disclosures, and licensed issuance, but with differences in requirements for international issuers and state regulatory authority limits.

Overall, these two acts do not have substantive conflicts; they are more like "complementary partners": the "GENIUS Act" sets up the framework, clarifying the regulatory jurisdiction and development direction for stablecoins; the "STABLE Act" completes the details on transparency and accountability, focusing on user fund safety.

Having understood the history of U.S. stablecoins, friends can shift their perspective to evaluate the recent ANPRM released by the U.S. Department of the Treasury regarding the formal advancement of the "GENIUS Act." This public comment request covers almost all aspects of the stablecoin ecosystem, focusing on six major topics: first, the qualification definition of issuers (including the "equivalent regulation" determination for foreign issuers); second, the rules for holding and disclosing reserve assets; third, the scope of extraterritorial applicability (compliance requirements for foreign institutions serving the U.S.); fourth, anti-money laundering and marketing restrictions; fifth, federal income tax characterization; and sixth, the prohibition on interest payments (including disputes over indirect payments). Currently, feedback is still being collected, and while conclusions are difficult to form, there are several core topics that the Sa Sister wants to discuss with everyone.

First, who is qualified to issue stablecoins is a key question that determines whether USDT can remain in the U.S. market. The "GENIUS Act" stipulates that only officially licensed "payment stablecoin issuing institutions" can issue coins in the U.S. Therefore, one core topic in the Treasury's inquiry is "who can issue payment stablecoins in the U.S." According to the GENIUS Act, only licensed payment stablecoin issuers (PPSI) can issue such stablecoins in the U.S. The ANPRM also asks for public feedback on whether additional definitions are needed and whether to open a "green channel" for small transactions.

For Tether, the company issuing USDT, if it does not meet these new requirements, it may only have three options: either rectify according to the new regulations, exit the U.S. market, or launch a new coin that complies with the regulations. Tether announced the launch of USAT, designed specifically for the U.S., which is essentially an attempt to meet regulatory conditions by "splitting its business." The regulatory standards for foreign issuing institutions have far-reaching implications; by questioning whether other countries' regulatory systems meet standards and the compliance capabilities of institutions, the U.S. is actually competing for the authority to set global stablecoin rules. In the future, foreign stablecoins that do not meet U.S. standards may find it very difficult to enter the U.S. market.

Second, whether stablecoins can provide users with returns is also a hotly debated issue. Although the act prohibits issuers from directly paying interest to users, it does not stop platforms like exchanges from providing indirect rewards. For example, the Coinbase platform offers users a 4% reward for holding stablecoins, which banks have opposed, accusing it of secretly attracting deposits and lobbying the government to change the rules. Regulatory agencies are inquiring whether "indirect interest payments count as violations," which is essentially a competition between traditional finance and the crypto industry for market share.

Ultimately, the "GENIUS Act" and the ANPRM are fundamentally about the U.S. wanting to incorporate stablecoins into the dollar hegemony system. The act aims to maintain the advantage of dollar stablecoins by tying them to U.S. Treasury bonds and establishing a framework, but claiming "hegemony realization" is overly optimistic. The crypto market is inherently decentralized, global regulation is competitive, and with the rise of Hong Kong and the promotion of offshore RMB stablecoins, I believe the U.S. cannot dominate.

Finally, I offer some practical advice to friends: first, closely monitor the feedback results of the ANPRM, especially regarding reserve custody and interest payment rules, as these directly affect the costs and liquidity of USDT and USDC; second, pay attention to the Hong Kong market, where offshore RMB stablecoins have valuation gaps, and early positioning may present opportunities. Currently, regulation and innovation are in a daily tug-of-war; understanding the rules and choosing the right track is essential to avoid capsizing in the wave of stablecoins.

Related: UK financial institutions and six major banks jointly pilot tokenized pound deposits

Original: “The Crypto Circle Focuses on ANPRM: Market Feedback to Rewrite the Fate of Stablecoins”

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