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NYDFS files 23 NYCRR Part 202 to align New York stablecoin regime with GENIUS Act
NYDFS proposed 23 NYCRR Part 202 on June 9 to bring New York's stablecoin regime in line with the GENIUS Act, opening issuance to limited purpose trust companies and requiring monthly CEO/CFO-certified reserve reports.

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NYDFS proposed 23 NYCRR Part 202 on June 9, 2026 to align state oversight with the federal GENIUS Act enacted in July 2025.
Limited purpose trust companies, charter applicants and superintendent-approved entities would be eligible to apply to issue payment stablecoins.
Existing issuers would have 12 months after the final rule takes effect to comply, excluding the certification requirement.
Authorized issuers would be required to publish monthly reserve composition reports, certified by their CEO and CFO.
The proposal faces a 10-day preproposal comment period and a subsequent 60-day comment period upon State Register publication.
NYDFS on June 9, 2026 proposed 23 NYCRR Part 202, a regulation governing payment stablecoin issuers that would take effect when the federal GENIUS Act of July 2025 becomes operative. The New York State Department of Financial Services stated that the proposed rule would carry forward existing stablecoin requirements while layering new compliance, governance and reporting obligations tied to the federal framework.
What does the proposed rule cover?
The proposal, set out in a NYDFS press release and accompanying draft text, applies to "authorized" payment stablecoin issuers operating under state supervision. NYDFS indicated the rule preserves three existing pillars of New York's stablecoin regime: redemption rights, reserve assets, and independent audit reviews. The new text adds a federal-grade overlay on top of those standards.
Who can issue payment stablecoins?
Limited purpose trust companies, applicants for a limited purpose trust company charter, and other entities the superintendent deems eligible could apply to issue payment stablecoins. Applicants would need to demonstrate financial resources and qualified leadership before receiving authorization.
NYDFS clarified that issuers already authorized before the rule's effective date would not need fresh approval to keep issuing their approved stablecoins, but would have to comply with the new rule within 12 months. The 12-month clock excludes the certification requirement.
What new operational requirements are imposed?
The proposal introduces seven categories of new obligations for authorized stablecoin issuers:
- Reserve custody: maintain reserves with eligible financial institutions.
- Reserve transparency: publish monthly reports on reserve composition, with each issuer's CEO and CFO certifying accuracy.
- Redemption: policies and timing standards.
- Capital: capital and operational backstops.
- Compliance: prohibited activities, BSA/AML, sanctions and consumer protection obligations.
- Governance: internal audit, risk management, internal controls, plus cybersecurity and customer-notice duties.
- Supervision: examinations, records, reporting, enforcement, plus insolvency and custody rules.
How does the regulatory timeline work?
NYDFS stated that the proposal is subject to a 10-day preproposal comment period, followed by a 60-day comment period after publication in the State Register. Existing New York-licensed issuers would then receive a one-year transition window once the final regulation takes effect.
The federal GENIUS Act, enacted in July 2025, sets the state-level template the proposal mirrors. NYDFS has signaled that the state regime will become operational only after the federal statute's effective date.
What changes for issuers and applicants?
For incumbent issuers, the operational effect is incremental: they keep their approvals but absorb new monthly reporting, CEO/CFO certification, and expanded compliance obligations within a year. For new entrants, the proposal opens a clearer pathway through limited purpose trust charters and superintendent approval, conditioned on capital and leadership vetting.
The combined 12-month state transition window and the pending federal GENIUS effective date set the operational horizon for New York's stablecoin industry to realign with federal standards.
via jdsupra.com (Original)
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