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Treasury Allows Conditional Stablecoin Filings Before State Rules Complete

The Treasury's interim final rule permits states to submit conditional stablecoin certifications by the initial deadline even as regulatory work continues, though only complete submissions trigger the federal review process.
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Treasury Allows Conditional Stablecoin Filings Before State Rules Complete

The U.S. Treasury has issued an interim final rule allowing states to file conditional or incomplete stablecoin certifications to meet initial filing deadlines while their regulatory frameworks remain under development.

Under the rule, which took effect September 30, states can preserve their path toward approval by submitting an initial certification on time and completing their work before substantive review begins. However, only complete and unconditional submissions will trigger the 30-day federal approval-or-denial clock.

Filing Requirements and Process

Conditional filings can be amended at any time without initiating substantive review. To advance to formal approval consideration, a state must provide an unconditional attestation signed by an authorized representative, a detailed explanation of how its regime meets Treasury's similarity principles, supporting legal materials, and any information the review committee deems necessary.

The Stablecoin Certification Review Committee, a federal body responsible for evaluating state stablecoin regimes, will review filings to determine whether they meet or exceed standards outlined in the GENIUS Act. State-qualified payment stablecoin issuers with no more than $10 billion in consolidated outstanding payment stablecoin issuance may opt for state regulation if approved.

Timeline and Next Steps

Certifications will not be accepted until after Paperwork Reduction Act approval of the information collection, with Treasury to announce when acceptance begins. The rule sets January 18, 2028 as the deadline for initial certifications, based on the expected January 18, 2027 effective date for the GENIUS Act, though this date could move earlier if federal regulators issue final payment stablecoin regulations sooner.

State-regime certification does not automatically grant licenses to individual stablecoin issuers. Comments on the interim procedures are due November 30.

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