Under the GENIUS stablecoin framework signed last year, issuers are required to:
• Fully back tokens one-to-one
• Hold reserves in cash or short-term US Treasuries
• Avoid leverage entirely
• Prohibit lending or fractional reserve practices

Coinbase argues this structure makes stablecoins structurally simpler and potentially more transparent than traditional banking systems.

Unlike banks operating with maturity transformation and leverage, stablecoin issuers are expected to maintain direct reserve backing with monthly attestations and visible on-chain transaction records.

The debate now centers on whether regulators will ultimately treat stablecoin issuers more like payment companies, banks, or an entirely new financial category altogether.