are identifiable;
are segregated from and not commingled with other assets owned or held by the Stablecoin Issuer; at all times have a total fair value that equals or exceeds the outstanding issuance value of the Stablecoin Issuer; and are either held directly by the Stablecoin Issuer or within the custody of an eligible financial institution.
Eligible Reserve Asset Categories
The Proposed Rules specify categories of permissible reserve assets consistent with the GENIUS Act, including:
U.S. coins and currency or money standing to the credit of an account with a Federal Reserve Bank; 11
deposits or insured shares payable upon demand at an insured depository institution;
U.S. Treasury bills, notes or bonds (“Treasuries”) with a remaining maturity of 93 days or less; money received from an overnight repurchase agreement (with the Stablecoin Issuer acting as the seller of securities) 12 collateralized by Treasuries with a maturity of 93 days or less; overnight reverse repurchase agreements (with the Stablecoin Issuer acting as the purchaser of securities) that are collateralized by Treasuries, “subject to overcollateralization in line with standard market terms”; 13 shares of investment companies registered under the Investment Company Act of 1940, as amended (“1940 Act”), “or other registered Government money market fund[s],” and that are invested solely in the type of eligible reserve assets enumerated above; 14 11 The Federal Reserve has requested public comment on a special purpose Reserve Bank account prototype (colloquially known as a “skinny master account”) tailored to the risks and needs of payments institutions. See Federal Reserve, Request for Information and Comment on Reserve Bank Payment Account Prototype , 90 FR 60096 (Dec. 23, 2025). 12 The Proposing Release notes that money from intraday repurchase agreements and intraday reverse repurchase agreements would be eligible reserve assets under the Proposed Rules. 13 Reverse repurchase agreements must also be either (i) tri-party; (ii) centrally cleared; or (iii) bilateral with a counterparty that the Stablecoin Issuer has determined to be adequately creditworthy even in the event of severe market stress. 14 Although registered government money market funds are eligible to be held as a reserve asset, the GENIUS Act imposes more stringent maturity requirements than those included in Rule 2a-7 under the 1940 Act (“Rule 2a-7”).
March 2026 / Page 7
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