StableClarity Network Reference
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Stablecoin Issuance

Permitted Payment Stablecoin Issuer

The GENIUS Act created a new federal licensing category for stablecoin issuers. PPSI defines who can issue, what reserves they must hold, and how the OCC examines them. This is the reference site for the institutions navigating it.

Legislative Framework

GENIUS Act — PPSI provisions

Section 2 — Definitions

What qualifies as a "payment stablecoin"

The Act defines a payment stablecoin as a digital asset pegged to a fixed monetary value, issued by a PPSI, and redeemable at par on demand. Algorithmic stablecoins are explicitly excluded.

Section 3 — Chartering

Federal vs. state chartering paths

Issuers above $10B in outstanding stablecoins must obtain a federal charter from the OCC. Below $10B, state-chartered issuers operate under state regulatory frameworks with federal backstop provisions.

Section 104 — Reserves

HQLA reserve composition requirements

PPSIs must maintain 1:1 reserve backing in high-quality liquid assets: US Treasury securities, Treasury repo, insured deposits, and central bank reserves. The specific composition tiers vary by charter size and type.

Section 5 — Examination

OCC examination and enforcement authority

The OCC conducts safety and soundness examinations of federally chartered PPSIs, including reserve audits, operational risk assessments, and consumer protection compliance reviews.

Market Landscape

Expected PPSI charter applicants

Incumbent issuer

Circle (USDC)

$75B+ in circulation. Already operates under state money transmitter licenses. Federal charter would consolidate regulatory posture and enable Arc L1 integration as a PPSI-compliant settlement chain.

Incumbent issuer

Paxos (USDP / PYUSD)

NY DFS-regulated trust company. Issues USDP and operates PayPal's PYUSD infrastructure. Federal charter aligns with existing bank-grade compliance posture.

New entrant

Bridge (Stripe)

Acquired by Stripe for $1.1B (2024). Stripe's stablecoin infrastructure play. Tempo L1 launch positions Bridge as both issuer and settlement chain operator.

Anticipated

Bank applicants

JPMorgan (Kinexys deposit tokens), BNY Mellon, and potentially one or more regional banks. The GENIUS Act explicitly enables national banks to issue payment stablecoins under existing OCC authority.

Reference Architecture

PPSI reserve composition and attestation flow

Interactive reference architecture diagram — reserve composition tiers, attestation workflows, and OCC examination checkpoints.

BUILDING — SVG + interactive version coming

Cloud Reference Architecture

PPSI compliance infrastructure on Cloudflare

Reference deployment topology: reserve attestation Workers, KV-backed compliance state, D1 for audit trails, R2 for document storage. Cloud-agnostic conceptual architecture alongside.

BUILDING — Cloudflare-native + cloud-agnostic diagrams coming