A Federal Reserve proposal published in the Federal Register on Sept. 29 would cap payment stablecoin redemptions by Board-supervised issuers at two business days. Researchers at the Andersen Institute for Finance and Economics, meanwhile, counted $76 billion of reserve-backed stablecoins sitting at identified centralized exchanges in a July 28 snapshot — a pool the proposed two-day clock does not directly reach.

The Andersen team located the $76 billion across 12 reserve-backed dollar stablecoins. The snapshot includes $61.5 billion of USDT and $10.1 billion of USDC at identified exchange wallets, with the remainder spread across the other 10 coins tracked.

What does the proposed rule actually require?

The Board announced the proposal on Sept. 24 and published it five days later. Under proposed section 247.12, a Board-supervised payment stablecoin issuer would have to disclose its redemption procedure and process requests within two business days under normal conditions.

The issuer would also explain how a customer can redeem and accept requests for at least one token, subject to screening and onboarding. The Board retains authority to extend the period for safety, financial stability or public-interest reasons. The proposal carves out limited safe harbors for delays tied to required customer checks or circumstances outside the issuer's control.

The rule remains under public comment.

Why doesn't the two-day clock cover the full $76 billion?

The Fed text addresses issuers under Board supervision; the Andersen tally measures balances at exchange venues. A customer instructing an exchange to sell, convert or withdraw operates under the venue's terms, not the issuer's.

The current terms at the three largest issuers illustrate why the distinction matters:

• Circle's USDC terms make direct redemption available to eligible holders outside the European Economic Area who hold a Circle Mint account in good standing. Holders without that account must first become eligible and registered. Circle describes Mint as a service for institutional distributors.
• Coinbase's U.S. user agreement states a customer "owns the balance" of a USDC wallet but that Coinbase "is not obliged to repurchase USDC for dollars." The agreement reserves the right to suspend sending or trading and directs customers to Circle for direct redemption.
• Tether requires a verified customer for direct redemption and posts a $100,000 minimum on its fees page, putting another share of the $76 billion effectively out of reach for retail customers without that verification.

How did exchanges behave during the March 2023 USDC stress event?

The Andersen researchers traced venue balances during a known historical shock. Using March 9, 2023 as a pre-shock baseline, they found exchanges held 15.2% of USDC supply but accounted for 40% of the subsequent supply decline — a disproportionate effect at the venue layer.

The timing matters. From March 10 to 13, USDC supply fell $2.7 billion while identified exchange balances rose $600 million, suggesting net tokens moved onto exchanges as overall supply contracted. After March 13, supply fell another $8.1 billion and exchange balances fell $4.9 billion — a larger and later venue-side contraction.

That sequence complicates any read of the episode as a clean, immediate exchange exodus.

What comes next?

The Board's comment period will determine the rule's timeline. Once closed, the final rule's reach will hinge on which issuers the Board actually supervises, how it defines eligibility, and whether it expands the exceptions. Until then, customer exit times remain a function of venue terms, and the Andersen snapshot will need a fresh read to track how the $76 billion figure moves under any new market structure.