Davis Polk associate Boaz Goldwater was featured on the New York City Bar Association’s podcast discussing the Treasury’s notice of proposed rulemaking implementing the GENIUS Act’s framework for regulating payment stablecoins. 

The episode highlights key ambiguities for issuers, including moving federal benchmarks, supervisory capacity, and unresolved capital and liquidity measurement issues; compares federal and state structures of banking and securities regulation, including “uniform” requirements versus areas with limited state calibration; and provides an overview of the inter-agency stablecoin certification review committee’s discretion, such as evolving OCC standards, and the ten billion outstanding issuance threshold triggering transition to OCC supervision with retained state oversight.

Explaining the purpose of this regulation, Boaz said, “This rulemaking is the Treasury’s attempt to provide those guidelines for what a permitted state pathway to being a qualified payment stablecoin issuer would look like.”

“The Genius Act and Payment Stablecoins: A Regulatory Deep Dive,” New York City Bar Association podcast (April 23, 2026)  

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