United States — License Map

The United States presents the most complex licensing environment in digital assets globally. There is no single federal framework equivalent to the EU's MiCA. Instead, regulation is distributed across at least six federal agencies (SEC, OCC, CFTC, FinCEN, FDIC, Federal Reserve) and 50 state regulators, each asserting jurisdiction over different activities and entity types. A firm seeking to operate across custody, stablecoin issuance, and mining must navigate overlapping and sometimes contradictory requirements at both levels.

Regulatory Architecture

Federal Agencies

Key State Regulators

Landmark Federal Legislation

• GENIUS Act (S.1582, Public Law 119-27, signed July 18, 2025): First federal digital asset law. Establishes payment stablecoin framework; compliant stablecoins excluded from securities/commodity definitions. Effective January 18, 2027 (or 120 days after final regulations). Multi-agency implementing rulemaking is underway: OCC NPRM (Feb 25, 2026), NCUA NPRM (Feb 11, 2026), FDIC application-procedures NPRM (Dec 16, 2025), FDIC prudential NPRM (Apr 7, 2026), FDIC illicit-finance NPRM (May 22, 2026), and Treasury/FinCEN/OFAC joint AML/sanctions NPRM (Apr 8, 2026; comments due June 9, 2026). The Federal Reserve PPSI prudential NPRM remains outstanding as of June 2026 — the Fed's 2026 press-release index (fetched 2026-06-06) lists no stablecoin or PPSI rulemaking, leaving the Fed the only primary federal payment-stablecoin regulator yet to issue its NPRM.
• CLARITY Act (H.R. 3633, House-passed July 17, 2025): Divides SEC/CFTC jurisdiction -- SEC for digital securities, CFTC for digital commodities. Awaiting Senate.
• Executive Order (January 23, 2025): Affirms right to mine cryptocurrency and maintain self-custody. Prohibits CBDC development.

Activity Comparison Table

Multi-Activity Licensing

The US regulatory patchwork means that each activity is governed by different regulators with different licensing requirements. There is no single license that covers custody, stablecoin issuance, and mining simultaneously.

Entity Structuring for Multi-Activity Operations

Option 1: OCC National Trust Bank (Potential Unified Path)

The OCC national trust bank charter comes closest to a unified license for custody and stablecoin issuance:

• Custody: OCC trust banks may provide fiduciary custody, hold collateral, and conduct riskless principal crypto transactions (IL 1188)
• Stablecoin issuance: The GENIUS Act designates OCC-supervised nonbank entities as Permitted Payment Stablecoin Issuers (PPSIs)
• Mining: Not covered -- mining would require a separate entity or be conducted through an affiliate

Firms like Paxos demonstrate this model: NYDFS trust charter converting to OCC national trust bank, enabling both custody (fiduciary) and stablecoin issuance (USDP, PYUSD for PayPal) from a single regulated entity.

Option 2: Multi-Entity Structure

Most multi-activity firms use separate legal entities per activity:

Coinbase illustrates this: Coinbase Custody Trust Company (NYDFS trust charter, OCC application pending) for custody, separate entities for exchange operations, and licensed across multiple states and countries.

Option 3: State-Level Multi-License Approach

For smaller operations, a combination of:

• NY BitLicense (covers custody, exchange, transmission in NY)
• State MTLs (49 states for stablecoin distribution)
• FinCEN MSB registration (federal AML baseline)
• Local permits for mining operations

This approach costs less upfront ($1M-$3M vs. $6M-$28M+ for OCC) but offers narrower protections and no fiduciary powers.

Real-World Multi-Activity Entity Profiles

Approval Data Across Activities

OCC National Trust Bank (Custody + Stablecoin):

• 18 applications filed in 2025 alone (vs. <4/year average 2011-2024)
• 8 conditional approvals (Dec 2025-Feb 2026): Ripple, Circle, BitGo, Fidelity, Paxos, Bridge/Stripe, Protego, Crypto.com
• 0 public denials as of March 2026
• Pending: Coinbase, Morgan Stanley, Payoneer, Zerohash, World Liberty Financial
• Only Anchorage Digital Bank has progressed from conditional approval to fully operational status

NY BitLicense:

• ~34 license holders as of March 2024 (~28 unique businesses)
• At least 1 documented denial (Bittrex -- capital concerns, lax AML)
• At least 15 companies left New York rather than apply
• NY Comptroller audit (January 2024) found missing/outdated financial documentation and incomplete fingerprinting

FinCEN MSB Registration:

• 100% approval rate -- registration is not approval-based; enforcement is post-hoc

The State-by-State Problem

The United States has no federal licensing passport for digital asset businesses. Unlike the EU's MiCA framework, where a license in one member state covers the entire European Economic Area, a US license in one state confers zero rights in another.

Scale of the Problem

Workarounds

• NMLS (Nationwide Multistate Licensing System): A single portal for managing multi-state MTL applications. Reduces administrative burden but does not reduce the number of licenses needed.
• GENIUS Act state preemption (future): Once the SCRC certifies state regimes as "substantially similar" and PPSI status is granted, the GENIUS Act may partially preempt state MTL requirements for stablecoin issuers. Timeline: earliest 2027.
• OCC federal charter: National trust bank charters operate under federal authority, preempting some state licensing requirements for banking activities. However, states may still require separate licensing for non-banking activities.

State-Level Complexity for Mining Operations

Mining faces a distinct state-by-state challenge beyond financial licensing -- energy regulation and local zoning:

Operating While Applying

Consolidated Banking Access

The 2023 closures of Silvergate Bank and Signature Bank -- the two primary banking partners for crypto businesses -- created a severe banking access crisis. The landscape has partially recovered but remains challenging, particularly for firms without federal charters.

Current Banking Partners by Activity

Federal Reserve Access

Key Barriers

• 44% of financial institutions say they are ready to offer accounts to crypto businesses; 21% are already active (Elliptic 2025)
• ESG compliance increasingly a prerequisite for banking partnerships
• OCC-chartered entities face fewer banking access challenges than non-bank crypto firms
• Federal Reserve proposed permanently eliminating "reputation risk" as a supervisory factor (February 2026), which would structurally prevent future debanking episodes

Total Cost: Multi-Activity Operation

Scenario: US Entity Providing Custody + Stablecoin Issuance + Mining

Federal Path (OCC Charter + Mining Subsidiary)

State Path (Multi-License)

Trade-offs: The federal path costs 5-15x more upfront but provides fiduciary powers, qualified custodian status, potential Fed payment rail access, and a stronger "regulatory moat" for institutional clients. The state path is accessible to smaller firms but lacks fiduciary authority and requires managing 49 separate state relationships.

Regulatory Direction

Federal Trend: Decisively Pro-Crypto (2025-2026)

The federal regulatory posture has undergone a fundamental shift since January 2025:

• January 2025 Executive Order: Affirms right to mine and self-custody; establishes Strategic Bitcoin Reserve (~200,000 BTC)
• March 2025: OCC IL 1183 removes bank non-objection requirements; SEC confirms PoW mining is not securities activity
• April 2025: DOJ memo ends "regulation by prosecution"; FDIC and Fed withdraw restrictive crypto guidance
• July 2025: GENIUS Act signed into law (68-30 Senate, 308-122 House) -- first federal digital asset legislation
• December 2025: OCC conditionally approves 5 national trust bank charters; CFTC launches digital asset collateral pilot; FDIC issues PPSI application NPRM
• January-March 2026: SEC-CFTC sign historic MOU harmonizing jurisdiction; OCC issues GENIUS Act NPRM (Feb 25, 2026); NCUA issues GENIUS Act NPRM (Feb 11, 2026); Kraken receives first crypto-native Fed master account (March 4, 2026)
• April-May 2026: FDIC issues GENIUS Act prudential NPRM (April 7, 2026) and illicit-finance NPRM (May 22, 2026); Treasury (FinCEN + OFAC) issue joint AML/sanctions NPRM treating PPSIs as BSA "financial institutions" and mandating an effective sanctions compliance program (April 8, 2026; Federal Register April 10; comments due June 9, 2026); Digital Asset PARITY Act (H.R. 8899) formally introduced (May 19, 2026) — first dedicated digital-asset tax bill (proposed, not enacted)

State Trend: Diverging

• Pro-crypto states strengthening: Wyoming (12+ blockchain laws, SPDI charter, state stablecoin), Kentucky (HB 701 mining protections, tax exemptions), Texas (grid integration model)
• Restrictive states maintaining pressure: New York (Draft GEIS projects $10.6B in mining damages; proposed excise tax on mining electricity; $48.5M Paxos settlement), some local jurisdictions adding mining bans
• New compliance layers: California DFAL (July 2026) adds licensing requirement with $500K minimum bond, though pure miners likely exempt

Key Risks

1. Political durability: Nearly all federal changes were made through sub-legislative mechanisms (interpretive letters, staff guidance, no-action letters, executive action) rather than durable legislation. Only the GENIUS Act is statutory. A future administration could reverse much of the framework.
2. Tether compliance: The July 18, 2028 sunset for non-PPSI stablecoins creates a forcing function. Global USDT ($174B) holds reserves that include bitcoin, gold, and secured loans — assets not permitted under the GENIUS Act. Rather than restructure USDT, Tether launched a separate, GENIUS-Act-compliant US product — USAT — on January 27, 2026, issued by Anchorage Digital Bank (a federally chartered institution) with Cantor Fitzgerald as designated reserve custodian. USAT remains small-scale ($20M at launch versus USDC's ~$75B); whether it can scale, and what becomes of global USDT distribution to US persons after July 2028, are now the open questions.
3. Rulemaking delays: If final GENIUS Act regulations miss the July 2026 deadline, the January 2027 backstop date applies, compressing implementation timelines.
4. Tax friction: IRS still treats all stablecoins as property despite GENIUS Act exclusion from securities/commodity definitions. No de minimis exemption has been enacted. The Digital Asset PARITY Act (H.R. 8899), formally introduced May 19, 2026, would add a stablecoin de minimis / deemed-basis safe harbor, extend wash-sale rules to digital assets, and create a five-year staking/mining deferral election — but it is newly introduced proposed legislation that has not advanced out of committee.

Upcoming Milestones

Enforcement Precedents Across Activities

Major enforcement actions illustrate the consequences of non-compliance and define the boundaries of acceptable conduct:

Tax Reporting Obligations

Licensing and tax reporting are structurally linked in the United States: licensed brokers are the entities required to file information returns with the IRS. The Infrastructure Investment and Jobs Act (IIJA, P.L. 117-58, November 2021) imposed broker reporting obligations via IRC Section 6045, and final regulations (T.D. 9989, July 2024) designated Form 1099-DA as the information return for digital asset transactions. The firms that hold these licenses are the firms that must report.

Form 1099-DA -- Broker Reporting

The IRS introduced Form 1099-DA as the standardized information return for digital asset dispositions:

Who must file: Brokers that take possession of customer digital assets, including custodial digital asset trading platforms, digital asset hosted wallet providers, digital asset kiosks (ATMs), and certain processors of digital asset payments (PDAPs).

DeFi exclusion: Treasury Decision 10021 (December 2024) would have extended 1099-DA reporting to DeFi participants, but Congress repealed it via H.J. Res. 25 (signed April 10, 2025) under the Congressional Review Act. The IRS is permanently prohibited from issuing a substantially similar rule.

Key data elements reported on Form 1099-DA:

• Gross proceeds from dispositions
• Cost basis (from January 1, 2026)
• Date of acquisition and date of disposition
• Gain or loss amount
• Digital asset type and quantity
• Wash sale loss disallowed (Box 1i -- accommodates potential future legislation)
• Transaction ID

Reporting thresholds: There is no de minimis threshold for Form 1099-DA -- all reportable transactions by covered brokers must be filed regardless of amount. Backup withholding (24%) applies if the customer fails to furnish a valid TIN.

Transition Relief

On March 5, 2026, Treasury and IRS issued proposed regulations allowing brokers to furnish 1099-DA statements to customers electronically rather than requiring paper copies.

Penalties for Non-Compliance

Brokers that fail to file correct and timely Form 1099-DA returns face graduated penalties under IRC Sections 6721 (failure to file with IRS) and 6722 (failure to furnish to payee):

Intentional disregard of filing requirements carries a penalty of the greater of $630 per return or 10% of the amount required to be reported, with no annual cap.

Section 6050I -- $10,000+ Digital Asset Cash Reporting

IIJA Section 80603 amended IRC Section 6050I(d) to extend cash transaction reporting to digital assets. Businesses receiving more than $10,000 in digital assets in a single transaction (or related transactions) would be required to file Form 8300 within 15 days, reporting the sender's name, address, SSN, and transaction details.

Current status: As of March 2026, this requirement is not yet in effect. IRS Announcement 2024-04 stated it will not apply until final regulations are issued. Once effective, failure to comply carries penalties of up to $25,000 per violation and potential criminal penalties (up to 5 years imprisonment) for willful violations.

OECD CARF Implementation

The United States has committed to the OECD Crypto-Asset Reporting Framework (CARF). On November 14, 2025, Treasury submitted proposed regulations to the White House Office of Information and Regulatory Affairs (OIRA) for review.

The U.S. has indicated a longer implementation timeline than other jurisdictions: formal adoption is targeted for 2027-2029, with first automatic exchanges of taxpayer information between jurisdictions expected 2028-2029. This contrasts with the EU and many OECD members that began CARF implementation from January 1, 2026.

CARF will require Reporting Crypto-Asset Service Providers (RCASPs) -- which includes licensed exchanges, custodians, and brokers -- to collect and report user transaction data to the IRS for automatic exchange with treaty partner jurisdictions.

How Licensing Creates the Tax Reporting Infrastructure

The US tax reporting framework is built on top of the licensing infrastructure: only entities that take custody of customer assets are classified as brokers for 1099-DA purposes. This means that the same licenses that authorize digital asset activity also impose the obligation to serve as the IRS's information collection layer.

Key insight: DeFi protocols and non-custodial wallets are explicitly excluded from broker reporting following the CRA repeal of T.D. 10021. This means the tax reporting burden falls entirely on licensed, custodial entities -- reinforcing the regulatory advantage of operating within the licensing framework while creating a compliance gap for decentralized activity.

RWA / Security Token Platform Licensing

The United States regulates tokenized real-world assets through existing securities laws -- there is no standalone RWA or security token legislation. Tokenized securities (bonds, equities, fund units) are subject to the Securities Act of 1933 and the Securities Exchange Act of 1934. The SEC treats tokenized securities identically to their traditional counterparts under technological neutrality.

License Details

Requirements

Application Process

Ongoing Obligations

• FINRA membership and examination compliance for broker-dealers
• Reg ATS reporting (Form ATS-N) for marketplace operators
• SEC Rule 15c3-3 customer protection and reserve requirements
• BSA/AML program, SAR/CTR filing, OFAC screening
• Form 1099-DA broker reporting from 2025 (gross proceeds); cost basis from 2026
• Annual audited financial statements; SOC 2 Type II certification

Passporting

No US-wide passporting. Reg D 506(b)/(c) offerings and Reg A+ Tier 2 offerings preempt state registration under NSMIA. Reg A+ Tier 1, Reg CF, and non-covered securities require state-by-state blue sky compliance. State notice filing fees typically $150--$750 per state.

Banking Access

SEC-registered broker-dealers and RIAs have established banking relationships. Institutional tokenized fund operators (BlackRock, Franklin Templeton) leverage existing banking infrastructure. Smaller tokenization startups face moderate banking difficulty similar to other fintech entities.

Key Holders

Transition

The SEC under the 2025-2026 administration has adopted a more permissive stance toward tokenized securities: SAB 121 was rescinded (removing balance-sheet barriers for custodied crypto), OCC is issuing conditional trust bank approvals at an accelerated pace, and the CLARITY Act (pending Senate passage) would clarify the CFTC/SEC jurisdictional boundary for digital assets. The institutional RWA tokenization market is growing rapidly, led by BlackRock BUIDL (>$2.5B), Franklin Templeton FOBXX, and expanding adoption by banks and asset managers.

See

DeFi Protocol Licensing

Regulatory Approach

The United States has no DeFi-specific license. DeFi protocols are regulated under existing financial laws applied on an activity-by-activity basis. The regulatory approach has shifted dramatically from enforcement-driven (2021-2024) to principles-based accommodation (2025-2026), anchored by the SEC/CFTC joint five-category token taxonomy published March 17, 2026.

Available License Types

DeFi-Specific Requirements

• Smart contract audits: Not federally mandated but effectively required for institutional participation and expected by regulators in enforcement contexts. SEC has cited lack of audits as evidence of inadequate controls.
• Governance framework: DAO governance tokens may be classified as securities if they confer profit expectations. The Ooki DAO enforcement action (CFTC, 2023) established that DAO token holders who vote on protocol operations can be held jointly and severally liable as an "unincorporated association."
• Decentralization threshold: The SEC/CFTC March 2026 taxonomy establishes that "sufficiently decentralized" protocols may fall outside securities regulation, but no bright-line test exists. The taxonomy allows non-security tokens initially sold as investment contracts to "graduate" as networks mature.
• OFAC compliance: Smart contracts interacting with sanctioned addresses risk enforcement. The Fifth Circuit ruled in Van Loon v. Treasury (November 2024) that OFAC exceeded its authority in sanctioning immutable Tornado Cash smart contracts, but mutable contracts remain sanctionable.

Key Enforcement Actions

Application Timeline

• FinCEN MSB: Immediate (online filing)
• State MTLs: 2-18 months per state; 18-24 months for full 49-state coverage
• SEC BD/ATS: 6-18 months
• CFTC DCM/SEF: 6-12+ months
• Innovation exemption: Not yet available; SEC Crypto Task Force developing framework

Cross-Reference

See

Sources: SEC/CFTC Joint Interpretive Release, Token Taxonomy (March 17, 2026); CFTC v. Ooki DAO, No. 3:22-cv-05416 (N.D. Cal. 2023); Van Loon v. Dept. of Treasury, No. 23-50669 (5th Cir. 2024)

Insurance / Risk Transfer Licensing

Overview

The United States has no federal mandate requiring crypto businesses to carry insurance against loss of customer digital assets. Insurance regulation is state-based, with each of the 50 states maintaining its own Department of Insurance. The absence of a federal framework means that digital asset insurance is governed by the same patchwork of state insurance laws that apply to all commercial insurance. The NAIC (National Association of Insurance Commissioners) has provided guidance through INT 21-01 (2021), which addresses the accounting treatment of crypto-asset holdings by insurers but does not create insurance requirements for crypto businesses themselves.

Regulatory Authority

Insurance Provider Licensing

Entities seeking to underwrite digital asset insurance in the US require:

• State insurance license in each state where policies are issued or risks are located -- there is no federal insurance license
• Surplus lines licensing for non-admitted carriers writing specialty digital asset policies (most crypto insurance is placed on a surplus lines basis because admitted market capacity is limited)
• Captive insurance options available in domiciles such as Vermont, Utah, and Hawaii for crypto firms seeking to self-insure portions of their risk

Insurance Requirements for Crypto Businesses

Captive Insurance Options

US crypto firms increasingly use captive insurance structures to address coverage gaps:

• Pure captives owned by a single crypto firm to insure its own risks (custody loss, crime, errors & omissions)
• Cell captives (protected cell companies) available in Vermont, Utah, and other domiciles for smaller firms sharing captive infrastructure
• Advantages: customised coverage terms, potential cost savings, retained underwriting profit, coverage for risks that commercial markets decline
• Limitations: capital must be committed; regulatory approval required; not a substitute for third-party insurance in the eyes of institutional counterparties

Named Insurance Providers Active in the US

Estimated Insurance Costs for Crypto Businesses

Regulatory Direction

• No federal insurance mandate for crypto businesses is expected in the near term; the GENIUS Act and CLARITY Act do not address insurance requirements
• The NAIC continues to monitor crypto-asset insurance through its Innovation, Cybersecurity, and Technology Committee but has not proposed model insurance requirements for crypto businesses
• State insurance regulators are increasingly scrutinising surplus lines placements for digital asset risks
• Captive insurance adoption by crypto firms is accelerating as commercial market capacity remains constrained relative to industry asset growth
• The SEC Custody Rule Modernization NPRM (expected April 2026) may address insurance expectations for qualified custodians of digital assets

Cross-Reference

See

Payment / Transfer Service License

Overview

The United States has no single federal payment license for crypto. Instead, crypto payment providers must navigate a three-layer licensing structure: (1) federal FinCEN MSB registration for AML/BSA compliance, (2) individual state money transmitter licenses (MTLs) in 49 states plus DC, and (3) optional federal charters (OCC national trust bank or GENIUS Act PPSI) that provide a higher-cost but more unified path. New York's BitLicense adds a fourth, crypto-specific layer. The GENIUS Act (signed July 18, 2025) creates a dedicated federal framework for payment stablecoin issuers but does not eliminate state MTL requirements.

License Details

Requirements

Application Process

Ongoing Obligations

Passporting & Cross-Border

Banking Access

Key License Holders

Transition / Grandfathering

Cross-Reference

See

Sources: FinCEN MSB Registration Rule; CSBS NMLS; NYDFS BitLicense; GENIUS Act (S.1582, Public Law 119-27); OCC GENIUS Act NPRM; Federal Reserve 2026 press releases

NFT & Digital Collectibles

Activity type: NFT marketplace operation, NFT issuance, fractionalized NFT platforms

For Full Details

• Custody:
  United States -- Institutional Crypto Custody Regulations
• Stablecoin Issuance:
  United States -- Stablecoin Regulations
• Mining:
  United States -- Crypto Mining Regulations
• Digital Asset Taxation:
  United States — Digital Asset Taxation
• RWA Regulation:
  United States — RWA Regulation -- SEC registration, exemption frameworks, broker-dealer/ATS requirements, BlackRock BUIDL, institutional tokenization
• DeFi Regulation:
  United States — DeFi Regulation -- SEC/CFTC jurisdiction, token taxonomy, Howey test, enforcement actions, DAO liability
• Digital Asset Insurance:
  US Digital Asset Insurance -- state-based insurance regulation, surplus lines, NAIC INT 21-01, captive insurance, institutional custody programmes
• Crypto Payment Regulation:
  US Crypto Payment Regulation -- FinCEN MSB, state MTLs, NY BitLicense, GENIUS Act, OCC PPSI, banking access, cross-border payments

Related coverage

United States — License Map in other research domains:

• CBDC Frameworks
• Crypto Mining Regulations
• DeFi Regulation & Liability Frameworks
• Digital Asset Insurance & Risk Transfer
• Digital Asset Taxation
• Institutional Crypto Custody Regulations
• NFT & Digital Collectibles Regulations
• Payment Services & Crypto Payment Regulation
• Stablecoin Regulations & License Regimes
• Tokenized Real-World Assets (RWA) Regulation

Verification Notes

This file was refreshed and reconciled on 2026-06-04 against the nine refreshed deep-research source-domain files for the United States (all dated modified: 2026-06-04). Licence types, regulators, fees, capital, bond, timeline, and effective-date facts were cross-checked against those sources; remaining facts were verified against primary regulator/legislative sources.

Corrections made this cycle (Correction Protocol)

1. GENIUS Act source URL — fixed. The Payment / Transfer Service License section previously linked the GENIUS Act to congress.gov/bill/119th-congress/senate-bill/394/text (S.394, an earlier February 2025 version, not the enacted bill). Corrected to the enacted bill, S.1582 (Public Law 119-27), at congress.gov/bill/119th-congress/senate-bill/1582. Confirmed via the refreshed stablecoin-regulations source (lines 33, 50, 53) which records S.394 as the February 4, 2025 earlier version and S.1582 as the May 21, 2025 final version signed July 18, 2025.

2. Tether compliance — corrected stale framing. The Key Risks and Activity Comparison sections previously stated that "whether Tether ($174B USDT) can comply" was "the largest open question," with no mention of Tether's response. Corrected to record that Tether launched a separate, GENIUS-Act-compliant US product — USAT, issued by Anchorage Digital Bank with Cantor Fitzgerald as reserve custodian — on January 27, 2026 (~$20M at launch vs. USDC ~$75B), rather than restructuring global USDT. Per refreshed stablecoin-regulations source (lines 400, 651, 880, 1001).

Developments added (2026-03-20 → 2026-06-04)

• FDIC GENIUS Act prudential NPRM — April 7, 2026 and FDIC illicit-finance NPRM — May 22, 2026. Per refreshed stablecoin-regulations source (line 993).
• Treasury (FinCEN + OFAC) joint AML/sanctions NPRM — issued April 8, 2026; Federal Register April 10, 2026; comments due June 9, 2026. Treats PPSIs as Bank Secrecy Act "financial institutions" and, for the first time in federal law, mandates that this category of US persons maintain an effective sanctions compliance program (five OFAC core elements). Verified via Treasury press release sb0435 (search-confirmed) and Federal Register 2026-06963.
• Digital Asset PARITY Act (H.R. 8899) — formally introduced May 19, 2026. First dedicated digital-asset tax bill: would extend wash-sale rules to digital assets, add a stablecoin de minimis / deemed-basis safe harbor, a five-year staking/mining deferral election, and a dealer mark-to-market election. Proposed legislation, not enacted — newly introduced, not advanced out of committee. Per refreshed digital-asset-taxation source (lines 77, 446, 451).
• OCC GENIUS Act NPRM dated to February 25, 2026 and NCUA NPRM to February 11, 2026 (previously stated only as "Jan–Mar 2026"). OCC date verified via OCC Bulletin 2026-3 (fetched 2026-06-04); NCUA per refreshed stablecoin-regulations source (line 993).

Unverified / flagged

• All cost, fee, capital, bond, timeline, and premium figures are self-reported or estimated (industry estimates, regulator-published where available). OCC charter application fees are NOT publicly disclosed; the "$5M–$28M+" all-in setup and "$6M–$28M+ first-year" PPSI figures are industry estimates flagged as such in the refreshed crypto-custody and stablecoin-regulations sources. State MTL all-state cost ranges ($250K–$350K Year 1; $225K–$280K+ annual) are aggregated industry estimates.
• BitLicense holder count. This file cites "~34 license holders (~28 unique businesses), as of March 2024"; the refreshed crypto-payment-regulation source cites "~25 entities holding BitLicenses or trust charters" as of 2025. The two figures count differently (license holders vs. BitLicense + trust charters) and use different vintages; both retained with their stated dates rather than silently merged.
• Federal Reserve PPSI prudential NPRM had not been issued as of 2026-06-06 — confirmed this cycle against the Fed's 2026 press-release index (no stablecoin/PPSI rulemaking listed). The Fed remains the only primary federal payment-stablecoin regulator yet to issue its NPRM. (Negative status verified against a primary; see gap-closure entry below.)

Targeted gap-closure pass (2026-06-06)

Two carried-forward gaps were closed against fetched primary sources this cycle:

1. Federal Reserve PPSI prudential NPRM status — confirmed outstanding (CLOSED). Previously flagged as outstanding but resting on cross-cutting facts rather than a live primary check. Re-confirmed this run by fetching the Federal Reserve Board's 2026 press-release index (fetched 2026-06-06), which lists no GENIUS Act / stablecoin / payment-stablecoin-issuer rulemaking among 2026 releases. Status carried forward unchanged (no Fed NPRM as of 2026-06-06); the difference is that the negative is now backed by a fetched primary rather than inference.
2. GENIUS Act statutory identity (S.1582 / Public Law 119-27) — verified via govinfo, bypassing the congress.gov 403 (CLOSED). The prior cycle could not fetch congress.gov (HTTP 403). This run fetched the enacted slip-law HTML at govinfo.gov PLAW-119publ27, which confirms: Public Law 119-27, originating bill S. 1582, short title "Guiding and Establishing National Innovation for U.S. Stablecoins Act" (GENIUS Act), approved July 18, 2025. The file's existing identity claims were correct; the source citation in the consolidated Sources block was switched from the 403-blocked congress.gov page to the fetched govinfo slip law.