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- The Fed wants supervised stablecoins fully backed by liquid reserves and subject to capital rules.
- The CFTC is allowing eligible tokenized investments deeper into regulated derivatives infrastructure.
- Blockchain can now serve as the primary recordkeeping system for CFTC-regulated firms.
Two U.S. regulators moved on opposite sides of the tokenization stack on September 24. The Federal Reserve proposed its first reserve, capital and approval rules for payment stablecoin issuers under the GENIUS Act, while CFTC staff further opened existing derivatives infrastructure to tokenized investments and blockchain-based recordkeeping.
The distinction is important. The Fed is writing rules for a new form of regulated private money. The CFTC is deciding when existing financial assets and records can move onto blockchain without losing their existing regulatory treatment.
The Fed Puts Redemption Before Innovation
The Federal Reserve’s first proposal starts with a straightforward requirement: a payment stablecoin must have sufficient assets behind it to meet redemption demands.
Board-supervised payment stablecoin issuers would have to fully back their outstanding tokens with permissible reserves, including short-term Treasury bills and certain other high-quality, liquid assets.
The proposal would also introduce standardized capital requirements covering specified credit and operational risks, along with broader risk-management standards. Separate provisions address Fed-supervised firms that safeguard stablecoin reserves and clarify which related activities supervised banks can conduct.
Governor Michael Barr summarized the underlying test: “Stablecoins will only be stable if they can be reliably and promptly redeemed at par in a range of conditions.”
That includes periods of market stress.
Barr noted that even otherwise liquid government debt can come under pressure and called for feedback on whether the proposal sufficiently addresses interest-rate and foreign-currency risks. He also said clear universal redemption rights would be important in the final framework.
The reserve requirement therefore addresses more than whether an issuer owns enough assets on paper. The harder question is whether those assets remain available quickly enough when many token holders want dollars at the same time.
Banks Face a Separate Test Before They Can Issue
The Fed’s second proposal concerns who gets to issue payment stablecoins.
A Fed-supervised bank seeking approval to issue them through a subsidiary would have to submit a business plan, financial information and other application materials.
The proposal also establishes procedures for appeals, hearings and final decisions.
That creates two regulatory gates.
One evaluates the stablecoin itself through reserves, capital and risk controls. The other evaluates whether the institution behind it is equipped to run the business.
Neither proposal is final. The public comment period closes 60 days after publication in the Federal Register, and Barr has already indicated that additional work will be needed as regulators implement the GENIUS Act.
Two Regulators, Two Parts of the Onchain Stack
Sources: Federal Reserve Board and Commodity Futures Trading Commission, September 24, 2026.
The difference between those approaches becomes clearest in the CFTC’s updated guidance.
The agency is not creating a new category of eligible customer investments simply because an instrument exists onchain. Instead, staff is addressing whether an investment already permitted under CFTC rules can retain that status when represented by a token.
Tokenized Funds Enter Existing Derivatives Rules
CFTC staff updated its crypto and blockchain FAQs with four new answers and one revision covering customer funds, margin and recordkeeping.
Futures commission merchants and derivatives clearing organizations can invest customer funds in tokenized versions of otherwise permitted investments when the token represents the same legal rights as the conventional asset.
Tokenized government money market fund shares are included, subject to applicable requirements, including written acknowledgment from the custodian.
That principle also reaches uncleared swaps.
Swap dealers can use qualifying tokenized money market fund shares as margin when the underlying fund satisfies existing requirements.
But the CFTC drew a clear line around native crypto assets.
Crypto, including stablecoins, still cannot be used to satisfy margin requirements for uncleared swaps.
A tokenized government money market fund and a stablecoin may both exist on blockchain rails, but their legal claims remain different. The CFTC’s treatment follows those underlying rights rather than the technology used to record them.
That gives tokenization a potentially easier path into regulated derivatives markets than crypto-native collateral.
A firm does not necessarily need regulators to recognize an entirely new asset category. It needs the tokenized instrument to preserve the legal characteristics of something the rules already permit.
Blockchain Can Become the Official Record
The recordkeeping update pushes that principle beyond financial assets.
CFTC-regulated brokers, exchanges and clearing organizations can use blockchain technology to satisfy regulatory recordkeeping requirements. A firm does not necessarily need to maintain an additional off-chain copy simply because the primary record exists onchain.
That makes the blockchain more than a settlement network.
It can become the official regulatory record.
The obligation to produce that record, however, remains with the regulated firm.
A company relying on a public blockchain must still be capable of retrieving and providing its records if the network becomes unavailable. Moving the database onto decentralized infrastructure does not transfer the firm’s compliance responsibility to the network.
That is a subtle but important shift.
Financial institutions have spent years experimenting with blockchain as an additional technology layer while conventional databases remained authoritative. CFTC staff is now acknowledging circumstances in which the distributed ledger itself can perform the recordkeeping function.
Tokenization Is Becoming a Question of Legal Substance
CFTC Chairman Michael Selig said earlier this week that U.S. markets need to prepare for “mass tokenization,” onchain finance and increasingly continuous markets.
The September 24 guidance gives that ambition a practical regulatory mechanism.
For existing financial instruments, tokenization can increasingly be treated as a change in format rather than legal substance, provided the token continues to represent the rights regulators already recognize.
The Fed faces the reverse problem with stablecoins.
A payment stablecoin is not merely an existing Treasury bill or bank deposit placed inside a blockchain wrapper.
It creates a new claim that users expect to exchange for dollars at par. Regulators therefore have to establish what reserves, capital, risk controls and institutional safeguards make that claim credible.
The result is a clearer division of labor emerging across U.S. onchain finance.
The CFTC is showing how existing financial assets and regulatory records can migrate onto blockchain infrastructure without abandoning their established legal framework.
The Fed is defining what a new form of blockchain-based money must contain before regulated institutions can issue it at scale.
If those approaches survive rulemaking and implementation, the next stage of tokenization may depend less on whether regulators accept blockchain technology and more on a narrower question:
What legal claim sits underneath the token?
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