Historical report: Originally published November 10, 2026, at 15:03 (UTC+8). The figures below are primarily as of June 30, 2026.
A research note by the Bank Policy Institute (BPI) found that only two of the 10 largest U.S. dollar stablecoins—Circle’s USDC and Paxos’s PYUSD—held reserves consistent with the GENIUS Act’s requirements for payment stablecoins. Together, they represented 26% of the sample’s circulation. BPI said two more represented 2% and were expected to meet the requirements, while the remaining 72% comprised offshore-issued stablecoins (65%) and crypto-backed stablecoins (7%).
That is an assessment of reserve composition, not a finding that every coin in the sample is legally subject to the act. According to the report, the GENIUS Act takes effect on January 18, 2027. Its reserve rules for payment stablecoins issued in the United States or offered to U.S. users permit assets including U.S. Treasury securities with no more than 93 days remaining to maturity, overnight reverse repurchase agreements backed by Treasuries and bank deposits. The law also provides a route for foreign issuers to serve U.S. users if the U.S. Treasury determines their home-country regime is comparable and the issuer demonstrates an ability to comply with U.S. legal orders.
How BPI assessed the market
BPI examined the 10 largest dollar stablecoins by circulation, which it said accounted for 97% of the market on June 30, 2026. Reserve data generally came from issuer disclosures; USDT disclosed quarterly rather than monthly, while BPI used Dune Analytics on-chain data for the crypto-backed USDS and DAI.
Four of the 10 were issued in the United States. BPI found that USDC and PYUSD met the reserve-asset criteria, but World Liberty’s USD1 and Ripple USD did not: both held money-market funds containing agency securities and longer-maturity Treasuries. BPI expected the latter two to meet the requirements.
For USDC, the report also described how reserves changed after the 2023 Silicon Valley Bank crisis. More than half of its uninsured bank deposits had been held at that bank, and USDC briefly fell to $0.87 amid concerns about redemption. By July 2026, BPI said roughly 70% of USDC’s reserves were Treasury-backed reverse repos, with the remainder split approximately evenly between uninsured bank deposits and Treasury bills.
Offshore and crypto-backed reserves
BPI placed the largest share of circulation in the offshore-issued group, which it said was outside the act’s direct reserve requirements. As of June 30, 2026, it reported that USDT’s reserves were 61% Treasury bills and 10% Treasury-backed overnight reverse repos. Gold, listed equities, bitcoin, secured loans, term repo loans and other investments made up a combined 29%. For Paxos’s offshore-issued Global Dollar (USDG), BPI reported 53% government money-market funds, 42% Treasury bills and 5% bank deposits; it said the funds can hold securities that do not meet the act’s criteria.
In the crypto-backed group, BPI reported that Sky Protocol’s USDS reserves were 42% crypto-backed loans, 38% stablecoins and 20% tokenized real-world assets in June 2026. It also described Ethena Labs’ USDe as backed by a combination of tokenized real-world assets, yield-bearing stablecoins and crypto-backed loans on DeFi protocols. BPI did not expect stablecoins backed by crypto-collateralized loans to qualify as payment stablecoins under the act’s reserve rules.
BPI is a research organization representing the U.S. banking industry. Its conclusion about the relative risks of offshore and crypto-backed reserves should be read in that context. The report also cautioned that meeting the GENIUS reserve criteria does not guarantee a stablecoin will maintain its peg: stablecoins on both sides of its assessment have previously traded below $1.
Original report (Odaily), based on a BPI research note by Laurence Bristow and Eva Funaki.
