One Year Under the GENIUS Act: Wisconsin’s Opportunity

Executive Summary

I feel privileged to say I live in a place in the world where most of us never have to think about how money moves. The last time I can remember wondering about exactly this was when tap-to-pay had just been integrated with Apple products. I remember my jaw literally dropping when I saw a chic woman effortlessly lift her wrist to the payment terminal at Starbucks and pay with her watch. I thought she was the coolest person ever in my early twenties and, naturally, wondered, “How the hell did she do that? How did she even know she could do that? Why did I not know I could do that, too?” As you can imagine, it didn’t take much to impress me then. Now, however, I’m admittedly a bit more discerning.

Since those good ol’ days of not having to worry about much beyond my undergrad grades and ranking the house parties taking place the upcoming weekend, my understanding of payment processing has expanded. I was surprised to learn that we have a substantial amount of the machinery that runs it right here in Wisconsin. Fiserv, one of the largest payment processors in the world, has its headquarters in Brookfield¹⁵ — a lovely town I used to strictly associate with shopping and sushi. (I disclose the youthful ignorance on purpose — it’s the fastest way to show how far this world sits from most people’s attention.)

What matters, whether we advertise it or not, is that Wisconsin is already in the business of moving money.

Last summer, Congress wrote new rules for one of the newest ways to move it. On July 18, 2025, just over a year ago, the GENIUS Act became law with real votes from both parties (68 to 30 in the Senate, 308 to 122 in the House),¹ and it set the first national framework for payment stablecoins: dollar-pegged digital tokens designed to move value the way cash does, just faster and around the clock.

Here is what I want to argue, and I’ll say plainly up front that I’ve spent years working in this industry, so weigh my read accordingly. The GENIUS Act did not hand Wisconsin a stablecoin economy. It handed us a set of choices. Congress built the frame; what we build inside it is still up to us. A year in, we mostly haven’t.

If you take three things from this briefing, take these:

• The architecture is federal, but the build-out is optional, and part of it is ours to do. The law sets a floor, and states decide whom to invite to issue, and how to protect the people who use them.
• The rules aren’t finished. Most of them were supposed to be written within a year, and some of the biggest pieces, like the Federal Reserve’s and the Treasury’s, still aren’t.¹² This is binding law with an unfinished instruction manual.
• Wisconsin is still deciding by default. Other states have already moved.²⁰ We haven’t, which is a familiar pattern, only this time there’s a federal clock running.

The Road to GENIUS

Why a law became necessary

Two failures explain why Congress finally acted. In the spring of 2022, a stablecoin called TerraUSD promised to maintain its dollar value through clever math rather than backing it with real reserves. When confidence cracked, the math ran backward, and TerraUSD and its sister token collapsed together, erasing more than 90% of a market worth over $40 billion in about a week.² That was the lesson in what happens when a “stable” coin isn’t actually backed by anything you can touch.

The second lesson was subtler, and honestly, more unsettling. In March 2023, USDC — a stablecoin that was fully backed — briefly broke its dollar peg anyway, because roughly $3.3 billion of its reserves, about 8%, was sitting in Silicon Valley Bank when that bank failed. The coin fell to about 87 cents before the money cleared, and it recovered.³ So here is what the two stories teach together. A coin can call itself backed and still fail you. What it is backed by, and where that backing actually sits when a Friday goes bad, turns out to be the whole question.

The uncertainty before the law

For most of a decade, stablecoins grew up in a legal gray zone. The states did the day-to-day supervising through their money-transmitter rules. Federal agencies each touched a corner of it: one on money laundering, others through enforcement actions and the occasional interpretive letter. Nobody was clearly in charge. That ambiguity runs through the whole industry, and it will come up again.

Back in 2021, a federal working group told Congress to legislate and suggested letting only insured banks issue these coins.⁴ The idea stalled, partly because a bank-only door struck many people, across the aisle, as too narrow. This is the “ad hoc” patchwork that people in the industry, including Fiserv’s Matthew Savage, describe as having left “lingering questions of uncertainty over the market.”⁵

The compromise Congress reached

GENIUS settled the fight by widening the door rather than shutting it. Instead of banks only, the law created three ways to become a licensed issuer, then held all three to bank-like standards for reserves, disclosure, and supervision. That is roughly why it drew votes from both parties. Crypto did not get the anything-goes market its loudest voices had wanted, and the banks did not get the monopoly they asked for back in 2021. What passed lives in between. And it governs real money: stablecoins are now worth something like $300 billion, and two names most Wisconsinites have never heard of account for the bulk of it, Tether’s USDT and Circle’s USDC.⁶

What the Act Does

Who is allowed to issue

Under the law, only an approved issuer may put a payment stablecoin into the U.S. market, and it has to be one of three kinds: a subsidiary of an insured bank or credit union; a federally approved nonbank issuer supervised by the Comptroller of the Currency; or a state-approved issuer, operating under a state regime that the federal government certifies as “substantially similar” to its own.⁷

The state path comes with a hard ceiling. An issuer can stay under state supervision only while it has no more than $10 billion in coins outstanding. Cross that line, and it has to move up to the federal regime within about a year or get a waiver.⁸ That ten-billion-dollar mark is the seam where state and federal authority meet, and it decides which regulator a growing Wisconsin issuer would answer to.

MJ Sterling · mjsterling.org

The reserve rule

The heart of the law is almost boring, and the boringness is deliberate. Every stablecoin has to be backed one-for-one by safe, liquid assets: dollars, insured deposits, short-term Treasury bills maturing in 93 days or less, and a few close cousins. That backing stays separate from the company’s own money. It can’t be quietly loaned back out. And every month the issuer has to publish what is actually in the reserve, with an outside accounting firm checking the math.⁹ Nothing exotic, nothing hidden. The whole requirement reads as a direct answer to Terra, and to the weekend SVB took USDC down with it.

MJ Sterling · mjsterling.org

What it does for the people who use it

The law stacks up a few protections for ordinary users. An issuer has to post a plain redemption policy: how you get your dollar back, how long it takes, what it costs, and where to find those monthly reserve reports. It can’t market a stablecoin as FDIC-insured, or government-guaranteed, or legal tender, because none of those are true.¹⁰ And if an issuer goes bankrupt, the people holding its coins get first claim on the reserves, ahead of other creditors. I’d add one honest caveat there: “first in line” is the promise, but bankruptcy is messy, and some claims can still slip ahead in practice, so it’s a real protection that shouldn’t be oversold.¹¹

Who watches whom

Supervision is split on purpose. Federal regulators handle the national issuers. A bank’s stablecoin subsidiary answers to whatever regulator already oversees that bank. State-approved issuers answer to their states, and Washington keeps a backstop for real emergencies. If that sounds familiar, it should. It is roughly how American banking has been supervised for generations, now stretched to cover stablecoins, and it keeps states at the table. The hard part is the seam. Exactly where a state’s authority stops and Washington’s picks up is still being argued over,¹³ and that argument is where Wisconsin’s story actually starts.

MJ Sterling · mjsterling.org

The rules still being written

GENIUS is a frame that leaves its own fine print to the regulators. Most of that fine print was due within a year, by this past July. A year in, the record is uneven: the Comptroller and FDIC have each put out proposed rules, but the Federal Reserve hasn’t published its piece, and the Treasury hasn’t written the rules it owes for foreign issuers. The law fully switches on either 18 months after it passed, around January 2027, or 120 days after the final rules land, whichever comes first.¹² So this is binding law whose instruction manual is still being drafted, and that unfinished window is exactly when states are deciding what to do.

What the law does not do

It’s just as important to see what GENIUS leaves alone, because that empty space is where our choices live.

• It doesn’t erase state consumer protection. The law overrides state licensing for federally approved issuers, but it specifically leaves state consumer-protection law standing. Where one ends and the other begins is unsettled, and state regulators are already fighting over one provision they read as reaching too far into their turf.¹³ The state’s lane is real; its edges are blurry.
• It doesn’t let issuers pay you interest. An issuer can’t pay holders any interest or yield just for holding the coin.¹⁴ The open question, being fought over right now, is whether an exchange or an affiliate can pay you a “reward” the issuer itself can’t.
• It isn’t a government digital dollar. A central bank digital currency (CBDC) is specifically excluded. GENIUS governs private, backed tokens, not a Fed-issued dollar, and it shouldn’t be confused for one.
• It doesn’t make Wisconsin do anything. The law opens a state path; it does not require us to build one, host a single issuer, or lift a finger. The choice, and the cost of not making it, is ours. That’s the hinge.

Wisconsin Implications

We’re already in this business (Fiserv, Brookfield)

People tend to ask if Wisconsin should get into stablecoins, and I think that has the question backward. One of the largest payment processors on the planet, Fiserv, is headquartered in Brookfield.¹⁵ The pipes of American money movement already run partly through our state. So the real question isn’t how to chase an industry from a standing start — we’re not starting from zero. It’s whether our policy will catch up to a footprint we already have.

The people who move money for a living tend to talk about this in practical terms. As Fiserv’s Matthew Savage put it to me, GENIUS and the rules still coming give “banks, credit unions, merchants, and fintechs alike the rules of the road” for folding an “always-on, digitally native technology into the financial system,” and stablecoins let a company “reconsider just about every aspect of the money movement system, from cross-border payments to vendor invoicing and ecommerce payments.” He’s candid that the rules aren’t finished, but says he’s “largely encouraged by the direction” the regulators are taking.⁵

Strip out the jargon and you can see what all of it is for. Right now, moving money between businesses runs through a chain of middlemen. Paying an overseas supplier, settling an invoice, clearing a card swipe: each hop can take days, and each hop takes a cut. Savage points to stablecoins as a way around “the laborious and lengthy clearing and settlement processes” money movement has always demanded. Value that settles in seconds. At any hour. Without anyone waiting for the next business day to begin. If you run a Wisconsin manufacturer paying a supplier in another country, or a small shop that has watched a payment sit for three days while rent comes due, none of this is abstract to you.

And it isn’t only the plumbing. Fiserv has built its own dollar-backed stablecoin, FIUSD, meant to help banks and credit unions move tokenized dollars.¹⁶ That puts a Wisconsin company squarely inside the market GENIUS was written to govern. It isn’t a one-company story, either. We have a deep bench of institutions that move and hold money, from Johnson Financial down in Racine to a credit-union network more than a hundred strong that serves close to four million members.¹⁷ When people picture where stablecoin policy “happens,” they picture New York, or Washington, or a Wyoming charter. Wisconsin belongs in that sentence more than it thinks.

Our banks and credit unions

For Wisconsin’s banks and credit unions, the law opens a door that used to be locked, or at least painted shut: a bank subsidiary is one of the three legal ways to issue. Whether one of our chartered institutions can actually walk through that door depends partly on state law: does Wisconsin even let its chartered banks set up a stablecoin subsidiary? The Wisconsin Bankers Association has already flagged the shift for its members.¹⁸ The question for our state’s Legislature is: will we make this a place where a regulated, homegrown institution can take part, or will we leave that path defined only in Washington?

The DFI’s decision

Our Department of Financial Institutions has a genuine choice to make, not a form to file. For nearly a decade, it was state regulators like DFI who actually supervised this market, and the new law keeps them in that partner role. To open the state path, Wisconsin would need a regime certified as “substantially similar” to the federal one, run through DFI, along with the applications, exam procedures, and staff that implies. And doing nothing is itself a decision: it just sends every Wisconsin issuer straight to Washington.

The law we just modernized (Act 267)

This is where GENIUS touches us most directly, and it’s a little ironic. As covered in my last briefing overlooking the blockchain legislative landscape in our state, Wisconsin rebuilt its money-transmission statute around a national model law in 2023.¹⁹ Barely two years later, GENIUS overrides state money-transmitter licensing for compliant stablecoin issuers, so for this one product, part of the framework we just modernized has been lifted up to the federal level. State regulators have pushed back hard on one piece of this as “a dramatic intrusion on state authority.”¹³ The practical question for us is how much of that 2023 work still governs stablecoin activity here, and where our remaining authority, especially over consumer protection, now begins and ends.

The opportunity, and the clock

The opening is real, and it won’t stay open forever. Georgia, Florida, and Delaware have already passed laws to align with the federal framework, and the certification process has its own deadline out ahead of us.²⁰

The tools for it aren’t exotic, either. Wisconsin already modernized its money-transmission law in 2023, which is the foundation a state-issuer regime would sit on. Several other states took a step like that and paired it with a regulatory sandbox, a way to let a vetted company test a product under a regulator’s eye without shouldering the full licensing burden on day one. So most of what we would need already exists here in some form. Nobody has decided to put it together yet.

Every month Wisconsin waits, the expertise and the charters and the compliance jobs quietly settle somewhere else. To be clear, I am not saying the state should subsidize anyone or bet on a favorite coin. My argument is smaller and more stubborn than that. We should choose. Either we are a place where responsible issuers work under rules Wisconsin helped write, or we are a place that takes whatever the federal system happens to hand down. Both are decisions. Only one of them is being made on purpose.

What Comes Next

The dates that matter

If you want to follow this the way I do, watch this calendar:

• July 18, 2025 — GENIUS is signed into law.
• Early 2026 — the Comptroller of the Currency puts out its proposed rules.
• April 2026 — the FDIC puts out its proposed rules.
• July 18, 2026 — the one-year deadline for most rules. The Federal Reserve and the Treasury miss it.
• Around January 2027 — the law fully takes effect (eighteen months in), unless final rules trigger it sooner.
• Around January 2028 — the deadline for states to get their regimes certified.
• July 18, 2028 — the cutoff for foreign stablecoins: after this, U.S. platforms can’t offer a foreign coin whose issuer isn’t compliant.

MJ Sterling · mjsterling.org

The rulemaking to watch

The next real action is administrative, not legislative. The Treasury still owes the standards for how a state gets certified and the rules for foreign issuers, and how strictly it writes “substantially similar” will decide how much room states have to design their own approach. The Comptroller and FDIC proposals have to be finalized, and the Federal Reserve still has to weigh in on capital, on how fast a coin must be redeemed, and on how far that no-interest rule reaches. Until those land, everyone is planning against a moving target.

The 2028 cliff

One date on that calendar deserves pulling out, because it’s already reshaping the market. Starting July 18, 2028 — three years after the law passed — it becomes unlawful for a U.S. platform to offer a foreign stablecoin whose issuer doesn’t meet GENIUS’s rules. The largest stablecoin in the world, Tether’s USDT, is a foreign issuer, and by its own recent disclosures roughly a quarter of its reserves sit in assets the law wouldn’t count — gold, loans, even bitcoin.²¹ So the deadline isn’t theoretical. It is already forcing the biggest players to choose: clean up the reserves, or lose access to American users. Honestly, the Tether story itself matters less to Wisconsin than the pace it reveals. The federal framework has real dates and real teeth, and the market is already rearranging itself to meet them. The one part still left blank is ours.

The questions still open

• Where does federal licensing stop and state consumer protection start? That’s the big one for state authority.
• Can an exchange pay “rewards” the issuer can’t? The market is testing it now.
• How do bank-issued “tokenized deposits” fit next to stablecoins?
• And Wisconsin still hasn’t adopted the commercial-code update (UCC Article 12) that gives digital property clear legal treatment,²² an open item I flagged last time and a natural companion to any stablecoin decision.

What Wisconsin’s policymakers should watch, and decide

Three of these decisions are genuinely ours, not Washington’s. Do we build a certified state path through DFI, or send every issuer straight to the federal regime? Do we change state law so our own banks and credit unions can actually form these subsidiaries? And how do we define the consumer-protection role the law hands back to us? None of that asks Wisconsin to bet on a particular company or coin. It only asks us to answer, instead of running out the clock.

The Choice

Now, hopefully, you scroll away from this briefing with a deeper understanding of where we’re at with payment processing beyond, “That’s so cool and convenient!”

But come back to Brookfield with me for a second. The machinery that moves our money already has a Wisconsin address. We just don’t think about it. Stablecoins are a new set of pipes for that same old job, and last summer Congress finally wrote the code those pipes have to run on. In the last briefing I argued that Wisconsin tends to move when someone hands it a template or shows it a harm, and tends to stall whenever the task is to pick a direction for itself. Well, here is the template. It is on the books, it has dates attached, and it is waiting. We can treat the frame Congress built as a finish line and assume there is nothing left for us to do. Or we can treat it as a starting line. That is the entire decision. And whether we are paying attention or not, we are answering it right now.

Sources

1. Enactment & votes. GENIUS Act, Pub. L. 119–27 (July 18, 2025). Senate 68–30 (June 17, 2025); House 308–122 (July 17, 2025). GovInfo; GovTrack S318; H200; White House fact sheet.
2. TerraUSD collapse (May 2022). Congressional Research Service, “Algorithmic Stablecoins and the TerraUSD Crash”; Richmond Fed.
3. USDC / SVB de-peg (March 2023). CoinDesk; Chainalysis.
4. President’s Working Group, Report on Stablecoins (Nov. 2021). SEC / PWG; Morrison Foerster.
5. Matthew Savage, Fiserv. Statement provided to the author (email correspondence; publication permission on file).
6. Market size. Total stablecoin market cap ≈ $303 billion as of mid-July 2026 (USDT ≈ $184B, ~59%; USDC ≈ $73B, ~24% — together ~83%), off a May peak. Aggregated market data: Statista; StableCoin.com; Transak.
7. Three issuer pathways. GENIUS Act §§3, 7 (Pub. L. 119–27); Sidley Austin.
8. $10B state-issuer ceiling; 360-day transition. GENIUS Act §7 (enrolled text — verbatim “$10,000,000,000” and “not later than 360 days”).
9. Reserve requirements. 1:1 backing; Treasuries ≤ 93 days; segregation; no rehypothecation; monthly reserve report examined by a registered public accounting firm. GENIUS Act §4; WilmerHale; Arnold & Porter.
10. Redemption & marketing limits. No FDIC-insured / government-guaranteed / legal-tender claims; public redemption policy. GENIUS Act §§4, 19; Senate Banking Committee fact sheet.
11. Insolvency priority. Holders’ first priority as to reserves (§11); practical-recovery caveat. WilmerHale; Credit Slips.
12. Rulemaking status & effective date. OCC NPRM (early 2026); FDIC NPRM (Fed. Reg., Apr. 10, 2026); Federal Reserve and Treasury pending. Effective date §20. CSBS, “One Year of GENIUS Implementation”.
13. Preemption & §16(d). GENIUS preempts state licensing for federally approved issuers but not state consumer-protection law; CSBS calls §16(d) “a dramatic intrusion on state authority.” CSBS; K&L Gates.
14. Interest / yield prohibition. GENIUS Act §4 (verbatim: “any form of interest or yield”). CLS Blue Sky Blog.
15. Fiserv, Inc. Headquartered in Brookfield, WI; a leading global payments processor. Wisconsin Bankers Assn. directory; company profiles.
16. FIUSD. Fiserv’s dollar-backed stablecoin, announced June 2025; 1:1 backing in cash and short-term Treasuries; built on Paxos/Circle infrastructure; designed for banks and credit unions. Fiserv / BusinessWire; CNBC.
17. Wisconsin financial-institution density. Johnson Financial Group (Racine, WI). Wisconsin credit unions: 97 state-chartered as of Q1 2026 (Wisconsin DFI, Office of Credit Unions); 100+ counting federally-chartered, serving close to 4M members (CreditUnionsOnline).
18. Wisconsin Bankers Association on GENIUS. “The Stablecoin Shift: What the GENIUS Act Means for Wisconsin Banks”; “The Future of Money? Why Stablecoin Is the Next Big Banking Debate.”
19. 2023 Wisconsin Act 267. Money-transmission modernization (CSBS Money Transmission Modernization Act; Wis. Stat. ch. 217). See MJ Sterling, Briefing 001.
20. Peer-state action & certification deadline. Georgia, Florida, and Delaware enacted GENIUS-aligned requirements; state-certification deadline referenced ~Jan. 2028. CSBS, “One Year of GENIUS Implementation”.
21. Foreign-issuer cutoff (July 18, 2028) & Tether. GENIUS Act §18 (unlawful, three years after enactment, to offer a non-compliant foreign stablecoin). USDT reserve composition. CoinDesk.
22. UCC Article 12. The 2022 amendments (controllable electronic records) not yet adopted by Wisconsin. See MJ Sterling, Briefing 001.

Common questions

What is the GENIUS Act?

Signed in July 2025, it’s the first national law governing payment stablecoins — dollar-pegged digital tokens built to move value like cash, but faster and around the clock. It sets who may issue them, requires every coin to be fully backed by safe assets, and splits supervision between federal and state regulators.

How does the GENIUS Act affect Wisconsin?

It didn’t hand Wisconsin a stablecoin economy; it handed the state a set of choices — build a state path for issuers under local oversight, or route them all to federal regulators by default. It matters here because Wisconsin is already in this business: Fiserv, one of the world’s largest payment processors, is headquartered in Brookfield.

What are the three ways to issue a stablecoin under the law?

A subsidiary of an insured bank or credit union; a federally approved nonbank issuer supervised by the Comptroller of the Currency; or a state-qualified issuer supervised by its own state under rules certified “substantially similar” to the federal ones. The state path is capped at $10 billion outstanding — above that, an issuer must move to the federal regime.

What does the GENIUS Act require of stablecoin reserves?

Every stablecoin must be backed one-for-one by safe, liquid assets — cash, insured deposits, short-term Treasury bills, and close equivalents. Reserves must be kept separate from the company’s own money, can’t be loaned out, and must be reported monthly and checked by an outside auditor. The rule was written directly against the 2022 Terra collapse and the 2023 USDC de-peg scare.

A year in, what still isn’t decided?

Plenty. The Federal Reserve and Treasury missed the one-year deadline to write their rules. The line between federal licensing and state consumer protection is still being fought over. And Wisconsin hasn’t decided whether to build its own issuer path — or to adopt the commercial-code update (UCC Article 12) that would give digital property clear legal footing.