Federal tracker: every action since the GENIUS Act
Every federal action on digital assets and stablecoins since July 2025, from Treasury, the SEC, the CFTC, the bank regulators, FinCEN and Congress, with what each one means for Wisconsin. Current as of 2 October 2026.
At a glance
Fifteen months of federal rulemaking
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136federal actions
Rules, proposals, guidance, charters, statements and laws since the GENIUS Act became law on 18 July 2025.
Federal Register and agency releases
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6open comment periods
Federal dockets taking comments as of 2 October, the first closing 19 October.
Federal Register
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2027GENIUS takes effect
18 January 2027. No final federal GENIUS rule had issued by 2 October.
Pub. L. 119-27, sec. 20
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2028state filing deadline
18 January 2028 for a state stablecoin regime to file its certification.
12 CFR part 1522
Open now
Comment periods open today
Listed for reference. WDBC reports and explains these proposals; it takes no position on them here.
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Comments close 19 Oct 2026
GENIUS Act rules on payment stablecoin issuance, offer and sale (proposed 12 CFR part 1523)
Who may issue, and from 18 July 2028 which stablecoins exchanges and other providers may offer or sell to people in the United States.
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Comments close 20 Oct 2026
Regulation Crypto Assets (proposed)
Offering exemptions ($5 million for start-ups, $75 million per 12 months), an investment-contract safe harbor, and preemption of state registration for exempt offerings and some secondary trading.
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Comments close 3 Nov 2026
Transfer agent rules (proposed)
Covers crypto asset securities and transfer agents that keep records on a blockchain.
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Comments close 30 Nov 2026
State certification forms and procedures (interim final rule, 12 CFR part 1522)
Already in effect since 30 September. Sets how a state files its certification; any filing, even a conditional one, by 18 January 2028 meets the deadline.
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Comments close 30 Nov 2026
The Fed’s GENIUS Act responsibilities (R-1899)
Reserves, redemption, capital and custody for Fed-supervised issuers, anti-tying for all issuers, and backup authority over state-qualified issuers.
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Comments close 30 Nov 2026
Applications by state member bank subsidiaries to issue stablecoins (R-1900)
30-day completeness and 120-day decision clocks for subsidiaries of Fed-member state banks.
Also open without a fixed date: the SEC’s crypto custody proposal (comments due 60 days after Federal Register publication) and comments on its innovation exemption for tokenized securities venues.
Current as of 2 October 2026
What changed for Wisconsin
- Staking has a Commission-level federal answer. A joint SEC and CFTC release (No. 33-11412, effective 23 March 2026) says protocol staking, including custodial and liquid staking, is not the offer and sale of a security; restaking, custodian discretion and guaranteed rewards are outside it. The Department of Financial Institutions told the crypto study committee on 18 August that it views protocol staking as an unregistered security. Wisconsin’s securities law directs DFI to consider uniformity with federal standards (s. 551.608), and staking is the committee’s charge.
- Federal preemption of state securities registration is proposed. The SEC’s Regulation Crypto Assets would preempt state registration for offerings under its exemptions and for some secondary trading. The CLARITY Act passed the House 294–134, but Senate cloture failed 49–50 on 15 September 2026. It is not law.
- A state stablecoin framework now has a filing procedure but no final test. Since 30 September a state can meet the 18 January 2028 deadline with any certification, even a conditional one, once Treasury opens filing. The “substantially similar” principles are still a proposal. Wisconsin has no issuer statute; five states enacted one in 2026.
- What Wisconsin money transmitters may sell is being defined. Treasury’s proposal says that from 18 July 2028 exchanges and other providers may sell only stablecoins from permitted or qualifying foreign issuers. That reaches DFI’s chapter 217 licensees and any state-issued token.
- National trust charters are now a full alternative to state licensing. The OCC made 16 charter decisions covering about 20 digital-asset firms, including a trust bank in Chicago, and its Interpretive Letter 1192 says national banks need no state money transmitter license. It was decided on Iowa’s version of the same model law Wisconsin enacted.
- Wisconsin’s state banks face three federal rulebooks. The Fed, the FDIC and joint capital guidance apply depending on charter. Under the FDIC proposal, stablecoin reserve deposits are insured to the issuer, not passed through to holders, and tokenized deposits count as deposits. None of the GENIUS bank rules is final.
- Credit unions are still waiting. NCUA’s two GENIUS proposals are not final, though the Act’s 18 July 2026 rulemaking deadline has passed. Wisconsin credit unions are chartered by DFI’s Office of Credit Unions.
- Federal anti-fraud work lines up with the 2025 kiosk law. FinCEN’s kiosk notice and scam-center alert describe the fraud that s. 217.12 (2025 Wis. Act 226) targets. Anti-money-laundering standards for issuers are set federally; a state’s role is supervision and enforcement.
- No federal tax law has changed for staking. Form 1099-DA reporting began with 2025 sales. A bill to tax staking and mining as ordinary income cleared Ways and Means 38–5 but has not passed the House. Any change reaches Wisconsin income tax only when the Legislature updates conformity (s. 71.01(6)).
- Federal law bars a Fed retail digital currency through 2030. The ROAD to Housing Act (Pub. L. 119-101) bars the Fed from issuing a CBDC until 31 December 2030.
Timeline
Every federal action, newest first
Filter by agency. Each entry links to the official document.
October 20261 item
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Adviser and Regulated Fund Custody Rules; Crypto Custody Rules
The SEC proposed new Investment Company Act custody rules and amendments to the Advisers Act custody rule to address how registered advisers and regulated funds may custody crypto assets. The proposal would permit self-custody of crypto assets in certain circumstances, allow state trust companies to serve as custodians for client and fund crypto assets, and add Form ADV and Form N-CEN questions, including on tokenization.
Wisconsin. Relevant to Wisconsin state banks and trust companies supervised by DFI’s Division of Banking that may custody crypto assets for advisers, funds or broker-dealers.
Proposed by the Commission 1 Oct 2026 (Release Nos. IA-7023; IC-36353; File No. S7-2026-35; RIN 3235-AN46; Press Release 2026-100). Not yet published in the Federal Register as of 2 Oct 2026; comments will be due 60 days after FR publication. OPEN once published.
September 202616 items
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Forms and Procedures for Review of State Certifications by the Stablecoin Certification Review Committee
Treasury issued this rule for the Stablecoin Certification Review Committee. It sets the forms and procedures state payment stablecoin regulators use to submit an initial certification and annual recertifications under GENIUS Act sec. 4(c), with attestation forms in Appendices A and B (sec. 1522.10). The Committee says a state meets the statutory deadline of 1 year after the Act’s effective date (18 Jan 2028, assuming an 18 Jan 2027 effective date) by filing any form of certification by then, even a conditional or incomplete one, provided it shows the state is moving toward substantial similarity.
Wisconsin. Sets the filing mechanics and the 18 Jan 2028 initial-certification date that DFI, or any other Wisconsin state payment stablecoin regulator the Legislature designates, would use for a Wisconsin GENIUS framework.
Interim final rule, effective 30 Sep 2026. Comments due 30 Nov 2026. Docket TREAS-DO-2026-0562, RIN 1505-AC97. Creates 12 CFR chapter XV subchapter C, parts 1520 to 1522, with 1520 and 1521 reserved and part 1522 (Stablecoin Certification Review Committee) in effect. Certifications are not accepted until the information collection gets Paperwork Reduction Act approval; Treasury will post a notice on its website.
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Implementing the Federal Reserve Board’s Responsibilities Under the GENIUS Act
The Board proposed new 12 CFR part 247 for Board-supervised payment stablecoin issuers (such as subsidiaries of state member banks): reserve assets such as short-term Treasury bills, redemption, capital and risk management standards, plus rules for Board-supervised custodians of reserve assets and a tying prohibition that applies to all issuers. It also addresses the Board’s backup enforcement authority over State-qualified issuers in unusual and exigent circumstances and the transition and waiver process for uninsured State-chartered depository institutions, and clarifies stablecoin activities permissible for state member banks.
Wisconsin. Directly shapes a Wisconsin state regime: the Fed would hold backup enforcement authority over any Wisconsin State-qualified issuer, and its standards join the federal baseline against which the SCRC judges whether a state regime is “substantially similar” (state certification due by 18 Jan 2028).
Proposed. Comments due 30 Nov 2026. Docket R-1899, RIN 7100-AH29. Board release 24 Sep 2026 (bcreg20260924a).
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Application Procedures for Board-Supervised Insured Depository Institutions Seeking Approval for a Subsidiary To Issue Payment Stablecoins
The Board proposed the procedure an insured state member bank must follow to get approval for a subsidiary to issue payment stablecoins, including a business plan and financial information, statutory timeframes, and a process for appeals, hearings and final determinations.
Wisconsin. This is the federal path for a Wisconsin state member bank that wants a stablecoin subsidiary, distinct from a state-qualified issuer licensed by DFI under a future Wisconsin framework.
Proposed. Comments due 30 Nov 2026. Docket R-1900, RIN 7100-AH30. Board release 24 Sep 2026.
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Updated FAQs Concerning Registrant and Registered Entity Activities Relating to Crypto Assets and Blockchain Technologies
New and updated staff answers address investing customer funds in tokenized forms of permitted investments under Regulation 1.25 and using blockchain technology to meet recordkeeping duties under Regulations 1.31 and 45.2. They extend the tokenized collateral guidance to how FCMs and DCOs hold and record customer assets.
Wisconsin. Federal acceptance of blockchain records for regulated recordkeeping is relevant to Wisconsin’s treatment of digital records, including UCC Article 12, which Wisconsin has not enacted.
Staff FAQs, in effect (Press Release 9303-26). Issued by MPD, DMO and DCR; updates the 20 Mar 2026 FAQs.
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Order Granting Temporary Conditional Exemptive Relief, Pursuant to Section 36(a)(1) of the Securities Exchange Act of 1934, From the Definition of “Exchange” in Section 3(a)(1) of the Exchange Act for the Use of Certain Distributed Ledger Trading Venues for Tokenized NMS Stocks and From the Definition of “Dealer” in Section 3(a)(5) of the Exchange Act for Certain Liquidity Providers for Tokenized NMS Stocks, and Request for Comment
The Commission exempted ‘Tokenized Securities Venues’ from the definition of ‘exchange’ so they can trade tokenized NMS stock through permissioned automated market makers and liquidity pools, and exempted certain liquidity providers in those pools from the definition of ‘dealer’. The relief is conditional, with tiered caps (for example, 75 symbols and 0.25% of average daily volume for Tier 1 stocks), and asks for comment on all aspects.
Wisconsin. Tokenized securities rest on state commercial law for ownership and transfer; Wisconsin has not enacted UCC Article 12 (see the WDBC model-legislation catalog and 50-state survey).
Final order, issued 17 Sep 2026 (Release No. 34-106402; File No. 4-927; Press Release 2026-90, the ‘Innovation Exemption’). Effective 17 Sep 2026 until 17 Sep 2031. Comments invited; no closing date stated in the order.
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Application by Bastion Platforms Trust Company, LLC, New York, New York to Convert to an Uninsured National Trust Bank (Corporate Decision 1391)
The OCC conditionally approved conversion of a New York trust company to a national trust bank offering white-label stablecoin issuance, stablecoin custodial wallets, conversion and services to other regulated issuers.
Wisconsin. Another state-to-federal conversion of a stablecoin business, relevant to how a Wisconsin state charter would compare.
Conditional approval 18 Sep 2026.
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De Novo Charter Application: Catena Trust Bank, N.A., New York, New York (Corporate Decision 1392)
The OCC preliminarily approved a national trust bank offering custody, investment management, conversion, clearing and execution for fiat, securities and digital assets, including GENIUS-compliant payment stablecoins once the Act is effective.
Wisconsin. Part of a steady flow of federal digital asset trust charters that a Wisconsin state charter would compete with.
Preliminary conditional approval 18 Sep 2026.
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Application to Charter Agora National Trust Bank, New York, New York (Corporate Decision 1393)
The OCC preliminarily approved a national trust bank for Agora providing digital asset custody, payments across traditional and blockchain rails, and fiduciary advisory services for custody clients.
Wisconsin. Another stablecoin-linked federal trust charter that, under the OCC’s IL 1192 view, would not need a Wisconsin money transmitter license.
Preliminary conditional approval 18 Sep 2026.
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CFTC Letter No. 26-25: No-Action Position regarding Introducing Broker Registration Requirement under Section 4d(g) and Associated Person Registration Requirement under Section 4k(1) of the Commodity Exchange Act
The Market Participants Division made the Phantom position (Letter 26-09) available to providers of passive software generally. Subject to conditions, staff will not recommend enforcement for failure to register as an introducing broker when the software lets users trade with registered FCMs, IBs and DCMs.
Wisconsin. Federal relief for non-custodial software developers parallels how such developers are treated under Wisconsin’s MTMA-based Wis. Stat. ch. 217.
In effect, subject to conditions, until a Commission rulemaking or guidance on IB registration for software developers takes effect (Press Release 9300-26).
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Digital Asset Tax Certainty Act, H.R. 10357
A broad digital asset tax bill: a de minimis rule, basis equal to redemption value for qualified U.S. dollar stablecoins (GENIUS-permitted issuers), wash sale and constructive sale rules, lending and trader rules, broker changes and a voluntary disclosure program. Section 401 makes mining and staking income ordinary income sourced to the recipient’s residence but does not settle when it is recognized; section 402 lets investment trusts stake.
Wisconsin. Even if enacted, it would reach Wisconsin income tax only when the Legislature updates fixed-date IRC conformity (Wis. Stat. 71.01(6)); its stablecoin rule would cover GENIUS-permitted issuers, including state qualified issuers.
Introduced 14 Sep 2026 (Rep. Jason Smith and 8 cosponsors); ordered reported by Ways and Means with a substitute, 38-5, on 16 Sep 2026. Latest action as of 2 Oct 2026; awaiting House floor.
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H.R. 3633: Senate cloture vote on the motion to proceed
The Senate fell short of the 60 votes needed to begin debate on the market structure bill (cloture motion filed 8 Aug 2026). The pending motion to reconsider allows the Senate to hold the vote again.
Wisconsin. Until Congress acts, Wisconsin’s own securities (Wis. Stat. ch. 551) and money transmission (ch. 217) rules continue to govern crypto trading and staking offered to Wisconsin residents.
Cloture on the motion to proceed not invoked, 49-50 (Record Vote 234; three-fifths required), 15 Sep 2026. Sen. Tillis entered a motion to reconsider the same day. This is the latest action as of 2 Oct 2026; not enacted.
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Treasury Cracks Down on Transnational Criminal Organization Behind Cyber Scam Operations Targeting Americans
OFAC designated Xinbi Guarantee, a Burma-linked online marketplace, and related entities under its transnational criminal organization program in connection with cyber scam operations targeting Americans. The SDN entries list about 320 digital currency addresses, most of them on the TRON network.
Wisconsin. Adds a large set of wallet addresses to the sanctions screening that Wisconsin money transmitters and kiosk operators (Wis. Stat. ch. 217; kiosks under s. 217.12) must run.
Designations effective 9 Sep 2026 (OFAC recent action 20260909; Treasury press release sb0624). UNVERIFIED: the press release narrative (home.treasury.gov blocked automated access); designations confirmed on the OFAC recent-actions page.
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Transfer Agent Rules
The SEC proposed to modernize the rules for registered transfer agents, amending Forms TA-1 and TA-2 and rescinding an existing rule. The proposal addresses transfer agents that handle crypto asset securities or use distributed ledger technology as part of the master securityholder file, which is how issuer-tokenized securities are recorded.
Wisconsin. Tokenized securities rest on state commercial law for ownership and transfer; Wisconsin has not enacted UCC Article 12 (see the WDBC model-legislation catalog and 50-state survey).
Proposed. Approved 1 Sep 2026 (Release No. 34-106246; File No. S7-2026-30; Press Release 2026-81). Comments due 3 Nov 2026. OPEN.
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FinCEN Alert on Money Laundering Activity Associated with Digital Asset Investment Scam Centers (FIN-2026-Alert005)
FinCEN alerted financial institutions to money laundering tied to overseas scam centers that run digital asset investment (‘pig butchering’) scams, and gave red flags and SAR filing instructions. The companion trend analysis reviewed 33,904 BSA reports filed between 8 Sep 2023 and 31 Dec 2025, which identified about $12.7 billion in suspected scam-related activity. Money services businesses and depository institutions filed 96 percent of those reports.
Wisconsin. Relevant to DFI-licensed money transmitters and kiosk operators (Wis. Stat. ch. 217) and to Wisconsin banks and credit unions that file SARs on scam-related crypto transfers.
Issued 3 Sep 2026 with a Financial Trend Analysis, ‘Digital Asset Investment Scams: 2023-2025 Threat Pattern & Trend Information’. SAR key term FIN-2026-SCAMCENTERS.
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Application to Charter OpenReserve Bank, National Association, Salt Lake City, Utah (Corporate Decision 1389)
The OCC preliminarily approved a full-service national bank offering tokenized capability across deposit products, digital asset services and a planned stablecoin-issuing subsidiary.
Wisconsin. Tokenized deposits at an insured bank are an alternative to stablecoins that Wisconsin state banks could also pursue under DFI and FDIC or Fed oversight.
Preliminary conditional approval 2 Sep 2026.
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Application to Charter Revolut Bank US, National Association, Stamford, CT (Corporate Decision 1390)
The OCC preliminarily approved a national bank for Revolut that will offer deposits, credit, payments and digital asset services, including digital asset custody.
Wisconsin. A consumer app bank with crypto services under a national charter, competing with Wisconsin banks and ch. 217 licensees for retail customers.
Preliminary conditional approval 2 Sep 2026; the approval does not include the proposed retail foreign exchange business.
August 20267 items
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Regulation Crypto Assets
The SEC proposed a tailored offering regime for investment contracts involving crypto assets, with two Securities Act exemptions: up to $5 million over a four-year period (a ‘startup’ exemption) and up to $75 million in each 12-month period, with principles-based disclosure and, for the larger tier, financial statements and ongoing reports. It also proposed a conditional safe harbor under which a crypto asset meeting its conditions would be deemed not subject to an investment contract.
Wisconsin. The proposal would preempt state securities registration and qualification for offerings under its exemptions and for certain secondary trading, which would narrow DFI’s registration role under Wis. Stat. ch. 551 for those offerings (state antifraud authority is a separate question). Wisconsin’s Uniform Securities Act (ch. 551, administered by DFI’s Division of Securities) has its own registration and exemption rules; Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Proposed. Approved 18 Aug 2026 (Release Nos. 33-11434; 34-106150; File No. S7-2026-27; RIN 3235-AN38; Press Release 2026-76). Comments due 20 Oct 2026. OPEN.
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Comptroller Gould Discusses Digital Asset Innovation, GENIUS Next Steps
The Comptroller said the OCC had received 40 de novo charter applications in about 18 months, 23 involving digital asset activity, and that the OCC would have its final GENIUS rule out by November 2026.
Wisconsin. Indicates the timing of the OCC final rule that will anchor part of the federal benchmark for a Wisconsin state framework.
Remarks 19 Aug 2026 (News Release 2026-69).
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GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale
Treasury proposed rules for GENIUS Act sec. 3: who may issue a payment stablecoin in the United States, and when a digital asset service provider (such as an exchange) may offer or sell one. From 18 Jul 2028, providers could offer or sell to persons located in the United States only stablecoins from permitted issuers or from foreign issuers that qualify under sec. 18 (comparable home regime and OCC registration). Separately, from the Act’s effective date, a provider could not make available a foreign issuer’s stablecoin unless that issuer can and will comply with lawful orders. The proposal defines ‘located in the United States’, lists conduct that counts as issuing, offering or participating, sets conditions under which offshore activity falls outside the rule, and asks whether to add de minimis safe harbors, which it does not yet propose.
Wisconsin. Would govern which stablecoins Wisconsin-licensed money transmitters and exchanges (DFI, Wis. Stat. ch. 217) may offer to Wisconsin residents after 18 Jul 2028, including coins from any future Wisconsin-chartered state qualified issuer.
Proposed. Comments due 19 Oct 2026. Docket TREAS-DO-2026-0496, RIN 1505-AC95. Would add 12 CFR part 1523 (sections 1523.1 to 1523.5 plus Appendix A); the preamble says part 1522 was reserved for other regulations.
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Application to Charter World Liberty Trust Company, National Association, Bay Harbor Islands, Florida (Corporate Decision 1385)
The OCC preliminarily approved a national trust bank to issue and redeem the USD1 stablecoin, maintain its reserves and provide digital asset custody, taking over USD1 issuance from BitGo’s national trust bank.
Wisconsin. Shows a widely held stablecoin moving under a federal trust charter, outside any state-qualified regime such as one Wisconsin might adopt.
Preliminary conditional approval 14 Aug 2026.
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Regulatory Flexibility Agenda (Spring 2026)
The Spring 2026 agenda lists ‘Crypto Assets’ (RIN 3235-AN38) with a second NPRM stage, ‘Amendments to the Custody Rules’, and ‘Transfer Agents’ (NPRM October 2026), the last described as including rules on crypto assets and transfer agents’ use of distributed ledger technology. These correspond to Regulation Crypto Assets, the October 2026 custody proposal and the September 2026 transfer agent proposal.
Wisconsin. Wisconsin’s Uniform Securities Act (ch. 551, administered by DFI’s Division of Securities) has its own registration and exemption rules; Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Published 14 Aug 2026 (Release No. 33-11416; File No. S7-2026-16). Comments on the agenda invited by 14 Sep 2026 (closed). Informational.
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Franklin Templeton (custody of Franklin OnChain U.S. Government Money Fund shares)
Staff said it would not recommend enforcement under Investment Company Act Section 17(f) and Rule 17f-2 if Franklin Templeton funds hold shares of the Franklin OnChain U.S. Government Money Fund (a government money market fund whose transfer agent records transactions on one or more blockchains) under the described custodial arrangements, without complying with certain paragraphs of Rule 17f-2.
Wisconsin. Tokenized securities rest on state commercial law for ownership and transfer; Wisconsin has not enacted UCC Article 12 (see the WDBC model-legislation catalog and 50-state survey).
Staff no-action position, Office of Chief Counsel, Division of Investment Management. Applies subject to the representations in the letter.
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FDIC Approves Deposit Insurance Application for Augustus National Bank, N.A.
The FDIC approved deposit insurance for Augustus National Bank, which will serve digital asset and technology companies and plans to issue a stablecoin through a subsidiary if approved under GENIUS.
Wisconsin. An insured bank planning a stablecoin subsidiary, a model Wisconsin state banks can compare when weighing the FDIC subsidiary path.
Approved 4 Aug 2026, with conditions.
July 20265 items
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Agency Information Collection Activities: Proposed Information Collection; Comment Request; Applications for Licensing or Registration To Issue Payment Stablecoins Under the GENIUS Act
The OCC proposed a new information collection for applications by entities seeking to be licensed or registered to issue payment stablecoins under the GENIUS Act.
Wisconsin. The OCC application is a reference point for DFI when designing a Wisconsin state-qualified issuer application.
Comment period closed 25 Sep 2026.
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Reporting Forms and Instructions Associated With Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers
The FDIC sought comment on weekly stablecoin activity and reserve reports (PS-01, and short form PS-01a) and quarterly reports of condition and income (PS-02) for its supervised issuers.
Wisconsin. The reporting a stablecoin subsidiary of a Wisconsin state nonmember bank would file, and a reference point for any DFI reporting design.
Comment period closed 18 Sep 2026. OMB No. 3064-0225. FIL-38-2026.
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21st Century ROAD to Housing Act, H.R. 6644 (Title XI, Central Bank Digital Currency)
Section 1101 adds a section 16A to the Federal Reserve Act barring the Fed and Federal Reserve banks from issuing a central bank digital currency, or a substantially similar digital asset, directly or through intermediaries, until 31 Dec 2030. It exempts any dollar-denominated currency that is open, permissionless and private, and uses the GENIUS Act definition of digital asset.
Wisconsin. Leaves dollar digital payments to private issuers, which raises the importance of a Wisconsin state payment stablecoin framework and SCRC certification by 18 Jan 2028.
Law. Pub. L. 119-101; became law without the President’s signature on 11 Jul 2026 (presented 29 Jun 2026). The CBDC section expires 31 Dec 2030.
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Connectia Trust, National Association, New York, New York (Proposed), and Request to Waive Citizenship and Residency Requirements (Corporate Decision 1380)
The OCC preliminarily approved a national trust bank owned through Sony Bank to focus on dollar stablecoin issuance and reserve maintenance, custody of its own and selected other stablecoins, and transfers within a closed, permissioned platform.
Wisconsin. A non-crypto corporate group choosing a federal trust charter for stablecoin issuance rather than a state-qualified path.
Preliminary conditional approval 2 Jul 2026.
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Request for Comment on Novel ETFs
The Commission asked for public comment on ETFs that invest in innovative asset classes or use novel strategies, naming crypto assets and blockchain-enabled opportunities among them. It sought views on facilitating such products while protecting investors.
Wisconsin. Informational for Wisconsin investors and advisers; ETF shares are federal covered securities that DFI does not register under ch. 551.
Request for comment (Release Nos. 33-11426; 34-105808; IC-36228; File No. S7-2026-24; Press Release 2026-60, 30 Jun 2026). Comments were due 60 days after FR publication (31 Aug 2026 by count; the FR text printed the deadline as a placeholder). Closed. UNVERIFIED: exact closing date as shown on sec.gov.
June 202611 items
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Request for Comment on the Extension of Standard Futures Contracts to 24/7 Trading and on Perpetual Contracts Referencing Physically Delivered or Storable Energy Commodities
The CFTC requested comment on extending standard futures to 24/7 trading and on perpetual contracts referencing physical or storable energy commodities such as crude oil. It builds on the bitcoin perpetual order and asks about reference price reliability, surveillance, position limits, margin, clearing, settlement and customer protection.
Wisconsin. Shows how far 24/7 and perpetual designs, first approved for crypto, may extend into physical commodity markets used by Wisconsin agricultural and energy hedgers.
Comment period closed. Original deadline 27 Jul 2026, extended to 26 Aug 2026 at 91 FR 47158 (28 Jul 2026), which also sought comment on the NYMEX 24/7 oil contract the CFTC stayed on 9 Jul 2026.
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Definition of Huione Group, a Financial Institution Operating Outside the United States of Primary Money Laundering Concern
FinCEN proposed widening the definition of Huione Group in its section 311 rule to include H-Pay Service PLC, and to cover any ‘successor entity’. FinCEN’s finding that Huione Group is a primary money laundering concern does not change.
Wisconsin. Extends correspondent-account restrictions that Wisconsin state banks and credit unions must observe.
Proposed. Comments closed 27 Jul 2026. RIN 1506-AB75. No final rule found as of 2 Oct 2026. The existing special measure (31 CFR 1010.664) remains in effect.
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Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism and Sanctions Compliance Risk Management
In coordination with FinCEN and OFAC, the OCC proposed BSA and sanctions compliance standards for permitted payment stablecoin issuers under its jurisdiction, the piece left out of its March GENIUS proposal.
Wisconsin. Federal AML expectations that a Wisconsin state-qualified issuer regime would be compared against; DFI examines ch. 217 licensees for BSA compliance today.
Proposed. Comment period closed 24 Jul 2026. Not final as of 2 Oct 2026. RIN 1557-AF55.
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Permitted Payment Stablecoin Issuer Customer Identification Program
FinCEN and the four federal banking regulators jointly proposed to treat permitted payment stablecoin issuers as financial institutions under the Bank Secrecy Act and to require each to keep a customer identification program comparable to those required of banks and credit unions.
Wisconsin. A Wisconsin state-qualified issuer under a future state GENIUS framework would still be subject to these federal BSA and CIP rules; DFI already examines ch. 217 licensees for BSA compliance.
Proposed. Comment period closed 21 Aug 2026. Not final as of 2 Oct 2026. RIN 1506-AB74. Fed release 18 Jun 2026; FDIC FIL-29-2026.
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De Novo Charter Application and Request for Residency Waivers: Morgan Stanley Digital Trust, Purchase, New York (Corporate Decision 1378)
The OCC preliminarily approved a Morgan Stanley national trust bank to custody digital assets, buy, sell, swap and transfer them for clients, facilitate staking on a fiduciary basis and act as collateral administrator for affiliate digital asset lending.
Wisconsin. A large securities firm adding fiduciary staking through a federal charter, relevant to Wisconsin’s staking study and DFI’s securities view.
Preliminary conditional approval 18 Jun 2026.
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Request for Information: Identifying Regulations To Facilitate Innovation and Competition to Financial Products and Services for Fintech Firms
The CFTC asked the public to identify regulations, guidance, orders and no-action letters that unduly impede fintech firms, a term the executive order defines to include digital asset service providers, from partnering with regulated institutions, and items that could streamline applications. Responses inform the CFTC’s review under Executive Order 14405.
Wisconsin. Parallel federal fintech reviews may inform DFI’s approach under Wis. Stat. ch. 217 and to fintech partnerships with Wisconsin state banks and credit unions.
Comment period closed 9 Jul 2026. Issued 16 Jun 2026 (Press Release 9254-26) under Executive Order 14405.
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Agency Information Collection Activities: Proposed Information Collection; Reporting Forms and Instructions for Permitted Payment Stablecoin Issuers Subject to the Jurisdiction of the Office of the Comptroller of the Currency; Comment Request
The OCC proposed weekly and quarterly reporting forms for permitted payment stablecoin issuers and foreign payment stablecoin issuers under its jurisdiction and sought a new OMB control number.
Wisconsin. Shows the federal reporting cadence that a Wisconsin state regime’s issuer reporting may be compared against.
Comment period closed 11 Aug 2026.
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CFTC Letter No. 26-19: No-Action Positions Regarding Removal of Expiration Dates from Existing Digital Commodity Perpetual-Style Futures Contracts
The Division of Market Oversight allowed DCMs to remove expiration dates from existing perpetual-style digital commodity futures, converting them into true perpetual futures, without the usual Part 40 waiting period. Conditions included soliciting feedback from position holders, advance notice with a chance to exit, risk disclosures and no other material term changes.
Wisconsin. Affects crypto futures already available to Wisconsin traders through registered exchanges; no direct effect on state law.
Expired 30 Jun 2026 by its terms (Press Release 9252-26). Requesters: Bitnomial Exchange, LLC and Coinbase Derivatives, LLC.
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Bank Secrecy Act and Sanctions Compliance Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers
The FDIC proposed to require its supervised stablecoin issuers to follow FinCEN and OFAC AML/CFT, sanctions and reporting requirements, and to align its supervision and enforcement of those programs with FinCEN’s.
Wisconsin. Would apply to stablecoin subsidiaries of Wisconsin state nonmember banks.
Proposed. Comment period closed 4 Aug 2026. Not final as of 2 Oct 2026. RIN 3064-AG29. Board approval 22 May 2026.
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Policy Statement Concerning the Listing of Perpetual Contracts
The Commission described its views on listing perpetual contracts, issued alongside the order permitting a DCM to list a bitcoin perpetual as a futures contract. Perpetuals on asset classes not covered by that order should go through case-by-case Commission review under Regulation 40.3.
Wisconsin. Sets the federal approach to crypto perpetuals, a product Wisconsin does not separately regulate; Wis. Stat. 551.608 points DFI toward uniformity with CFTC practice.
Final. Adopted 29 May 2026; published 3 Jun 2026.
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H.R. 3633 as reported by the Senate Committee on Banking, Housing, and Urban Affairs (amendment in the nature of a substitute, including the Lummis-Gillibrand Responsible Financial Innovation Act of 2026)
The Banking substitute replaces the House text with a new Digital Asset Market Clarity Act whose Title I is the Lummis-Gillibrand Responsible Financial Innovation Act of 2026 (ancillary asset disclosures and exemptions), plus titles on illicit finance, banking, software developers and customer protection. It includes staking provisions (self staking, self-custodial staking, liquid staking and custodial staking services) and preempts state securities registration for covered exemptions and digital asset activities, while preserving state consumer protection law.
Wisconsin. Directly relevant to DFI’s securities jurisdiction under Wis. Stat. ch. 551 (preemption of state registration) and to the staking charge before the Wisconsin crypto study committee and AB 892.
Ordered reported favorably with a substitute on 14 May 2026; reported by Sen. Tim Scott on 1 Jun 2026 without written report; Senate Calendar No. 423. UNVERIFIED: committee vote count.
May 202614 items
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De Novo Charter Application and Request for Citizenship Waivers: Laser Digital National Trust Bank, New York, New York (Corporate Decision 1377)
The OCC preliminarily approved a national trust bank for Nomura’s digital asset unit to provide digital asset, securities and fiat custody, a staking service for custodied assets and customer-directed spot trading.
Wisconsin. Includes staking by a federally chartered trust bank, relevant to the Legislative Council study committee’s staking charge and DFI’s 18 Aug 2026 view on protocol staking.
Preliminary conditional approval 29 May 2026.
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CFTC Letter No. 26-16: Staff Advisory for Extending Trading and/or Clearing Operations to a 24 hours-a-day, 7 days-a-week Basis
Three CFTC divisions reminded DCMs, SEFs, DCOs and FCMs of their obligations when extending trading or clearing to 24/7, and set staff expectations. The advisory says crypto-referencing derivatives may be well suited to 24/7 trading, while markets such as agricultural products may be less suited.
Wisconsin. Round-the-clock crypto derivatives margin relies on settlement assets such as payment stablecoins, which ties to a Wisconsin GENIUS state framework; the agricultural caution is relevant to Wisconsin farm hedgers.
Staff advisory, in effect (Press Release 9239-26).
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Order Approving KalshiEX LLC BTCPERP Futures Contract
The Commission approved KalshiEX’s BTCPERP, a perpetual contract referencing the spot price of bitcoin, for listing as a futures contract on a DCM. Perpetuals on asset classes not contemplated by the order are to be submitted for Commission review case by case.
Wisconsin. Perpetual bitcoin futures are federally regulated derivatives outside DFI’s ch. 217 and ch. 551 jurisdiction; Wisconsin residents reach them through registered intermediaries.
Approved under CEA section 5c(c)(4) and Regulation 40.3 (Press Release 9240-26). Issued with the Policy Statement Concerning the Listing of Perpetual Contracts.
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CFTC Letter No. 26-17: Staff Interpretation Regarding the Categorization of Deribit Perpetuals as Foreign Futures and No-Action Position Regarding Digital Commodities and Payment Stablecoins Deposited to Margin Customer Positions with a Foreign Broker Under a Right of Re-Use
The Market Participants Division confirmed that certain crypto perpetuals listed on Deribit FZE, a Coinbase-affiliated foreign board of trade, may be treated as foreign futures under Regulation 30.1. It also took a no-action position letting the FCM post customer digital commodities and payment stablecoins with its foreign broker affiliate under a right of re-use.
Wisconsin. Lets U.S. customers, including Wisconsin residents, reach offshore crypto perpetuals through a registered FCM, with payment stablecoins usable as margin abroad.
In effect, subject to conditions (Press Release 9241-26). Requester: Coinbase Financial Markets, Inc.
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Paxos Securities Settlement Company, LLC; Order Granting an Application for Temporary Registration as a Clearing Agency Under Section 17A of the Securities Exchange Act of 1934
The Commission granted Paxos Securities Settlement Company temporary registration as a clearing agency for a settlement service that records ownership of eligible securities on a distributed ledger (the ‘Paxos Ledger’). The order notes it is one of several efforts, including DTC’s tokenization pilot, exploring tokenization of securities clearance and settlement.
Wisconsin. Tokenized securities rest on state commercial law for ownership and transfer; Wisconsin has not enacted UCC Article 12 (see the WDBC model-legislation catalog and 50-state survey).
Order (Release No. 34-105562; File No. 600-39). Temporary registration granted, with an 18-month exemption from certain requirements of Sections 17A(b)(3)(A) and (F); ramp-up limits apply.
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Proposed Revisions to the Federal Reserve Policy on Payment System Risk and the Guidelines for Account and Services Requests
The Board proposed a new Part IV of its Payment System Risk policy and changes to its Account Access Guidelines so Reserve Banks can offer “payment accounts” with no intraday credit, no discount window, no interest and automated overdraft controls. The Board also encouraged Reserve Banks to pause decisions on Tier 3 access requests until the policy is finished; RFI commenters included payments, crypto and stablecoin firms seeking access.
Wisconsin. Novel Wisconsin-chartered institutions that fall in Tier 3 (generally those not federally insured) face the paused review, which bears on any state-chartered stablecoin or trust entity seeking direct Fed access.
Proposed. Comment period closed 27 Jul 2026. Not final as of 2 Oct 2026. Board release 20 May 2026.
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Regulation A: Extensions of Credit by Federal Reserve Banks
Part of the payment account package, this proposal would amend Regulation A to state that a payment account holder is not eligible for discount window credit. Existing discount window programs and rates would not change.
Wisconsin. Relevant to any Wisconsin-chartered payments or stablecoin-focused institution weighing a payment account against a full master account.
Proposed. Comment period closed 27 Jul 2026. Not final as of 2 Oct 2026. RIN 7100-AH24.
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Regulation D: Reserve Requirements of Depository Institutions
Part of the payment account package, this proposal would amend Regulation D so that Reserve Banks pay no interest on balances held in payment accounts. Reserve requirement ratios stay at zero.
Wisconsin. Relevant to the economics of any Wisconsin-chartered payments or stablecoin entity holding balances at a Reserve Bank in a payment account.
Proposed. Comment period closed 27 Jul 2026. Not final as of 2 Oct 2026. RIN 7100-AH25.
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Integrating Financial Technology Innovation Into Regulatory Frameworks
The order directs the CFPB, SEC, NCUA, CFTC, FDIC and OCC to review rules, guidance and application processes that block fintech firms, including digital asset firms, from partnering with regulated institutions or getting charters and licenses, and then to act on what they find. It asks the Federal Reserve Board to evaluate whether uninsured depository institutions and non-bank firms, including digital asset firms, can have direct access to Reserve Bank payment accounts and services, and to report within 120 days.
Wisconsin. Charter and master-account changes would affect paths for Wisconsin-chartered institutions and DFI-licensed fintech and digital asset firms (ch. 217).
EO 14405, signed 19 May 2026, published 22 May 2026. Agency reviews were due within 90 days and follow-up steps within 180 days; the Federal Reserve was asked for a report on payment account access within 120 days.
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Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the National Credit Union Administration
NCUA proposed operating and risk management standards for NCUA-licensed stablecoin issuers, which it says align with those proposed for bank subsidiaries. It also addresses share insurance coverage, tokenized shares and conforming amendments.
Wisconsin. Sets share insurance treatment of tokenized shares and the stablecoin rules for subsidiaries of Wisconsin federally insured credit unions.
Proposed. Comment period closed 17 Jul 2026. Not final as of 2 Oct 2026 (the GENIUS deadline for implementing regulations was 18 Jul 2026). RIN 3133-AG10. NCUA release 15 May 2026.
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Electronic Furnishing of Payee Statements Regarding Digital Asset Sales by Brokers; Hearing
Scheduled a telephone public hearing on REG-105064-25, the proposed rule on electronic delivery of Form 1099-DA statements. Speakers had to submit outlines by 28 May 2026.
Wisconsin. Procedural step only; Wisconsin taxpayers and brokers are affected through the federal rule, not through state conformity.
Notice of public hearing set for 8 Jul 2026 (by telephone); outlines were due 28 May 2026, failing which the hearing would be cancelled. UNVERIFIED: whether the hearing was held (no cancellation notice found in the Federal Register).
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Interpretive Letter 1192: Applicability of State Money Transmitter Licensing Requirements
Responding to Fidelity Digital Assets, N.A. (a converted crypto trust bank) after an Iowa inquiry, the OCC concluded that the National Bank Act preempts state laws requiring a national bank to hold a money transmitter license, and that state visitorial claims conflict with 12 U.S.C. 484. The bank may operate in any state without a money transmitter license, whether or not it meets a state exemption.
Wisconsin. Directly relevant to Wis. Stat. ch. 217: Iowa’s law is the CSBS MTMA, the same model Wisconsin enacted in 2023 Act 267, so under the OCC’s view national trust banks would not need a DFI money transmitter license.
Letter dated 12 May 2026; listed in the OCC June 2026 interpretations and decisions.
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Application to Charter Augustus National Bank, National Association, Dallas, Texas (Corporate Decision 1374)
The OCC preliminarily approved a full-service national bank that plans tokenized deposits, digital asset services and a wholly owned subsidiary to issue dollar stablecoins.
Wisconsin. Shows the insured bank subsidiary path to stablecoin issuance, the federal counterpart to what a Wisconsin state bank could pursue through the FDIC or Fed.
Preliminary conditional approval 8 May 2026. FDIC approved deposit insurance 4 Aug 2026.
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HQLAx S.a r.l. and Clearstream International S.A. (use of a private, permissioned distributed ledger by U.S. participants)
Staff said it would not recommend enforcement under Exchange Act Section 17A(b)(1) (clearing agency registration) against HQLAx or Clearstream International for letting U.S. persons participate on their platform, which transfers securities on a private, permissioned distributed ledger. The letter is limited to the facts described in the request.
Wisconsin. Tokenized securities rest on state commercial law for ownership and transfer; Wisconsin has not enacted UCC Article 12 (see the WDBC model-legislation catalog and 50-state survey).
Staff no-action position, Division of Trading and Markets. Applies only to the facts presented.
April 20269 items
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Staff Statement Regarding Broker-Dealer Registration of Certain User Interfaces Utilized to Prepare Transactions in Crypto Asset Securities
Staff said it would not object if providers of certain front-end interfaces, including self-custodial wallets with such interfaces, help users prepare crypto asset securities transactions without registering as broker-dealers, if conditions are met. The conditions include letting users customize default transaction parameters, giving educational material, and not soliciting specific transactions.
Wisconsin. Wisconsin’s Uniform Securities Act (ch. 551, administered by DFI’s Division of Securities) has its own registration and exemption rules; Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Division of Trading and Markets staff statement. Treated as withdrawn five years from 13 Apr 2026 absent Commission action. Public comment file 4-894.
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Occupations That Customarily and Regularly Received Tips; Definition of Qualified Tips (T.D. 10044)
The final no-tax-on-tips regulations exclude all digital assets, including payment stablecoins, from the “cash tips” eligible for the new section 224 deduction. Treasury says it is still reviewing comments on its GENIUS Act ANPRM (90 FR 45159) about whether payment stablecoins should be treated as cash or cash equivalents for tax purposes, and may revisit this rule.
Wisconsin. An early federal tax position on payment stablecoins relevant to a Wisconsin state stablecoin framework under GENIUS; Wisconsin’s own treatment of the tips deduction depends on whether it updates IRC conformity (Wis. Stat. 71.01(6)).
Final. Issued 10 Apr 2026 (IR-2026-49); effective 12 Jun 2026.
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Prohibition on the Use of Reputation Risk by Regulators
The OCC and FDIC codified the removal of reputation risk from supervision and barred their staff from pushing institutions to close or deny accounts based on political, religious or similar views or lawful business activities. Commenters cited digital asset businesses among those affected by past debanking.
Wisconsin. Applies to FDIC examinations of Wisconsin state nonmember banks (jointly supervised with DFI) and to national banks in Wisconsin serving digital asset firms.
Final. Effective 9 Jun 2026. RINs 1557-AF34, 3064-AG12. Proposed at 90 FR 48825 (30 Oct 2025).
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GENIUS Act Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers and Insured Depository Institutions
The FDIC proposed reserve, redemption, capital and risk management standards for FDIC-supervised stablecoin issuers and rules for insured banks that provide stablecoin-related custody. Deposits held as stablecoin reserves would be insured as deposits of the issuer, not on a pass-through basis to stablecoin holders, and tokenized deposits that meet the statutory definition of deposit would be treated like any other deposit.
Wisconsin. Sets deposit insurance treatment of tokenized deposits and stablecoin reserve deposits for every Wisconsin insured bank, including any that hold reserves for a Wisconsin state-qualified issuer.
Proposed. Comment period closed 9 Jun 2026. Not final as of 2 Oct 2026. RIN 3064-AG19. Board approval 7 Apr 2026.
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Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements
FinCEN and OFAC proposed treating permitted payment stablecoin issuers as financial institutions under the Bank Secrecy Act. Issuers would need AML/CFT programs, sanctions compliance programs, and the technical ability to block, freeze and reject transactions, as the GENIUS Act requires. Issuers would be carved out of the money services business definition. The proposal would not require issuers to file SARs on secondary-market transactions, and it would not change the rules for other crypto businesses.
Wisconsin. A Wisconsin state qualified issuer would carry these federal duties, while ordinary Wisconsin crypto money transmitters stay under existing MSB rules and Wis. Stat. ch. 217.
Proposed. Comments closed 9 Jun 2026. Docket FINCEN-2026-0100, RIN 1506-AB73; would amend 31 CFR parts 502 and 1010 and create a new part 1033. Proposed compliance 12 months after the final rule. Released 8 Apr 2026. No final rule as of 2 Oct 2026.
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Effects of Stablecoin Yield Prohibition on Bank Lending
The Council of Economic Advisers modeled the GENIUS Act ban on issuers paying interest or yield to holders. Its model found that an effective yield ban would raise bank lending by about $2.1 billion (0.02 percent), with about $0.5 billion of that from community banks, at a net welfare cost of about $0.8 billion. The paper frames this against proposals in CLARITY Act versions to also bar affiliate or third-party yield.
Wisconsin. Bears on deposit and lending effects for Wisconsin community banks and credit unions, and on yield provisions a Wisconsin state stablecoin framework would need to mirror.
Council of Economic Advisers research paper released 8 Apr 2026; CEA published a follow-up FAQ responding to critics on 15 Sep 2026.
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Notice 2026-20: Extension of Temporary Relief Under Section 1.1012-1(j)(3)(ii)
Extends through 2026 the Notice 2025-7 relief that lets taxpayers identify which units of a digital asset held by a broker they sold by recording the choice (or a standing order) in their own books, rather than only by instruction to the broker. The taxpayer’s records control even if the broker’s Form 1099-DA reports different lots.
Wisconsin. Affects how Wisconsin residents compute federal gain on crypto held at exchanges in 2025 and 2026; the Wisconsin effect depends on fixed-date IRC conformity (Wis. Stat. 71.01(6)).
In effect. Relief period now runs 1 Jan 2025 through 31 Dec 2026. Published in I.R.B. 2026-15 (6 Apr 2026). UNVERIFIED: earlier IRS release date.
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GENIUS Act Broad-Based Principles for Determining Whether a State-Level Regulatory Regime Is Substantially Similar to the Federal Regulatory Framework
Treasury proposed the broad-based principles that GENIUS Act sec. 4(c) requires for deciding whether a state’s payment stablecoin regime is ‘substantially similar’ to the federal framework. States would still have some room to tailor their regimes. The principles would sit in a new 12 CFR part 1521, and the Stablecoin Certification Review Committee will apply them when it reviews state certifications.
Wisconsin. This is the test a Wisconsin state payment stablecoin framework would have to meet for SCRC certification, due by 18 Jan 2028.
Proposed. Comments closed 2 Jun 2026. RIN 1505-AC90; would be 12 CFR part 1521. Not finalized as of 2 Oct 2026: no later FR document under this RIN, and the 30 Sep 2026 SCRC IFR lists part 1521 as [Reserved].
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De Novo Charter Application and Request for Residency Waivers: Coinbase National Trust Company, New York, New York (Corporate Decision 1370)
The OCC preliminarily approved a national trust bank for Coinbase to provide digital asset custody as a fiduciary, mainly for institutional clients, with related transactional services for custody customers.
Wisconsin. The largest U.S. exchange obtaining a federal trust charter, an alternative to state trust or money transmitter oversight such as Wisconsin ch. 217.
Preliminary conditional approval 2 Apr 2026.
March 20269 items
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Fiduciary Duties in Selecting Designated Investment Alternatives
The Department of Labor proposed a rule clarifying the ERISA duty of prudence when fiduciaries pick investment options for participant-directed plans, with a process-based safe harbor. The rule would apply to any option, including asset allocation funds holding alternative assets such as digital assets. The preamble says there is no per se rule for or against vehicles that invest in digital assets.
Wisconsin. Affects private-sector 401(k) plans of Wisconsin employers; ERISA governs, so there is no state law hook.
Proposed. Comments closed 1 Jun 2026. RIN 1210-AC38; 29 CFR part 2550. Implements EO 14330 sec. 3(c). No final rule found in the Federal Register as of 2 Oct 2026.
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Application of the Federal Securities Laws to Certain Types of Crypto Assets and Certain Transactions Involving Crypto Assets
The SEC sorted crypto assets into five categories (digital commodities, digital collectibles, digital tools, stablecoins and digital securities) and said the first three are not themselves securities, although they can be sold subject to an investment contract that later ends. It concluded that protocol mining, protocol staking (solo, self-custodial with a third party, custodial, and liquid staking), wrapping and certain airdrops, as described, do not involve securities offerings, and that staking receipt tokens for non-security assets are not securities. The CFTC said it will administer the Commodity Exchange Act consistent with the interpretation and that certain non-security crypto assets can be commodities.
Wisconsin. Bears on the Wisconsin Legislative Council 2026 Study Committee on Cryptocurrency’s staking charge and on AB 892; DFI’s 18 Aug 2026 view is that protocol staking is an unregistered security, and Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Final; interpretation and guidance. Adopted 17 Mar 2026 (Release Nos. 33-11412; 34-105020; File No. S7-2026-09; Press Release 2026-30). Effective 23 Mar 2026. Supersedes the staff’s 2019 Framework for Investment Contract Analysis of Digital Assets and prior Commission and staff statements on these topics (meme coins, mining, protocol staking, liquid staking).
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CFTC Market Participants Division and the Division of Clearing and Risk Respond to Frequently Asked Questions Concerning Registrant and Registered Entity Activities Relating to Crypto Assets and Blockchain Technologies
Staff answers to questions about applying Letter 25-39 (tokenized collateral) and Letter 26-05 (digital assets as margin) for FCMs, DCOs and other registrants. The FAQs state they are staff views only and create no new rules.
Wisconsin. Operational detail on stablecoin and tokenized margin is relevant to any Wisconsin state payment stablecoin issuer seeking derivatives market use under GENIUS.
Staff FAQs, in effect; updated 24 Sep 2026 (separate entry). Press Release 9200-26.
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CFTC Letter No. 26-09: No-Action Position regarding Introducing Broker Registration Requirement under Section 4d(g) and Associated Person Registration Requirement under Section 4(k) of the Commodity Exchange Act
The Market Participants Division said it would not recommend enforcement against Phantom, a self-custodial crypto wallet software developer, for not registering as an introducing broker when its software lets users trade with registered FCMs, IBs and DCMs. The position is subject to specified conditions.
Wisconsin. Addresses the federal derivatives registration question for self-custodial wallet software, a parallel to how such software is treated under the MTMA-based Wis. Stat. ch. 217.
In effect, subject to conditions (Press Release 9197-26). Requester: Phantom Technologies Inc. Broadened to passive software providers generally by Letter 26-25 (17 Sep 2026).
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Memorandum of Understanding Between the U.S. Securities and Exchange Commission and the U.S. Commodity Futures Trading Commission Regarding Harmonization in Areas of Common Regulatory Interest
The two agencies agreed to coordinate and harmonize policy, examination and enforcement, including removing obstacles to the lawful introduction of crypto asset products. The accompanying Joint Harmonization Initiative lists a fit-for-purpose framework for crypto assets among its workstreams.
Wisconsin. Federal harmonization of the securities and commodities lines for crypto is the reference point for DFI under Wis. Stat. 551.608’s uniformity direction.
In effect (CFTC Press Release 9192-26). Created a Joint Harmonization Initiative. Also announced in SEC Press Release 2026-26.
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Electronic Furnishing of Payee Statements Regarding Digital Asset Sales by Brokers
Would let digital asset brokers obtain customer consent to receive Form 1099-DA statements electronically through an optional process, without having to offer a paper alternative. It also requests comments on related delivery questions such as combined statements.
Wisconsin. Affects how Wisconsin customers of crypto platforms receive their federal tax statements; it is a federal procedural rule, so no Wisconsin conformity change is involved.
Proposed (REG-105064-25), announced 5 Mar 2026 (IR-2026-29). Comments closed 5 May 2026. No final rule found in the Federal Register as of 2 Oct 2026.
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Capital Treatment of Tokenized Securities Frequently Asked Questions
The three federal bank regulators said the capital rule is technology neutral: an eligible tokenized security (one conferring legal rights identical to the non-tokenized form) gets the same capital treatment as the traditional security. It can count as financial collateral if it meets the usual definition, and treatment does not differ between permissioned and permissionless blockchains.
Wisconsin. Applies to every Wisconsin bank regardless of charter; the legal status of tokenized assets also intersects with UCC Article 12 (controllable electronic records), which Wisconsin has not enacted.
Issued 5 Mar 2026 (joint release; FDIC FIL-5-2026).
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National Bank Chartering
The OCC finalized its clarification that national trust banks may conduct non-fiduciary activities related to trust company operations, after receiving 19 comments. Later OCC decisions on digital asset trust banks describe non-fiduciary digital asset custody as trust company operations.
Wisconsin. Firms can rely on this rule to obtain a national trust charter for crypto custody instead of a Wisconsin trust charter or ch. 217 license.
Final. Effective 1 Apr 2026. RIN 1557-AF47.
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Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency
The OCC proposed the rules for permitted payment stablecoin issuers and foreign payment stablecoin issuers under its jurisdiction, and for certain custody activities of OCC-supervised entities. It covers all OCC GENIUS rules except BSA/AML and sanctions, which it proposed separately.
Wisconsin. The OCC rules for federal qualified issuers are a main federal comparison point for a Wisconsin state-qualified issuer regime under the “substantially similar” test.
Proposed. Comment period closed 1 May 2026. Not final as of 2 Oct 2026; the Comptroller said on 19 Aug 2026 a final rule would be out by November. RIN 1557-AF41. OCC release 25 Feb 2026.
February 202611 items
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Prohibition on Use of Reputation Risk or Other Supervisory Tools To Encourage or Compel Banking Organizations To Engage in Politicized or Unlawful Discrimination
The Board proposed to codify removal of reputation risk from its supervision and to bar examiners from pushing banks to deny services based on lawful but politically disfavored business activities. The proposal states the Board intends to include permitted payment stablecoin issuers within its scope.
Wisconsin. Would govern how the Fed examines Wisconsin state member banks that serve digital asset businesses, in parallel with DFI’s own supervision.
Proposed. Comment period closed 27 Apr 2026. No final rule found in the Federal Register as of 2 Oct 2026. RIN 7100-AH17. Board release 23 Feb 2026.
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Foris DAX National Trust Bank, Chicago, IL (Proposed), and Request to Waive Residency Requirements (Corporate Decision 1367)
The OCC preliminarily approved a national trust bank in Chicago for the Foris DAX group, which does business as Crypto.com, for digital asset custody and related services.
Wisconsin. A neighboring-state (Illinois) crypto trust bank with a federal charter that could serve Wisconsin customers without a Wisconsin license.
Preliminary conditional approval 20 Feb 2026.
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Division of Trading and Markets: Frequently Asked Questions Relating to Crypto Asset Activities and Distributed Ledger Technology (Q5, payment stablecoin net capital, NEW 2/19/26)
Staff said it would not object if a broker-dealer treats a proprietary position in a ‘payment stablecoin’ as having a ready market and applies a 2% haircut when computing net capital under Rule 15c3-1. Before the GENIUS Act takes effect, ‘payment stablecoin’ is defined in the FAQ by issuer type (state money transmitter, state trust company or national trust bank), GENIUS-style reserves, a published redemption policy and monthly reserve attestations; after it takes effect, by the GENIUS Act definition.
Wisconsin. Relevant to a Wisconsin state payment stablecoin framework under GENIUS (WDBC has a discussion draft; SCRC state certification due by 18 Jan 2028) and to DFI’s money transmission licensing under Wis. Stat. ch. 217 (CSBS MTMA, 2023 Wis. Act 267).
Staff FAQ, Question 5 added 19 Feb 2026. Staff views only.
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Form 1099-DA, Digital Asset Proceeds From Broker Transactions (2026), and Instructions for Form 1099-DA (2026)
Form 1099-DA is the information return custodial digital asset brokers file with the IRS and furnish to customers. Tax year 2025 was the first reporting year (gross proceeds only); for 2026 sales, brokers must also report cost basis for units acquired in 2026 or later, with optional aggregate reporting for certain stablecoin and NFT sales.
Wisconsin. Form 1099-DA is outside the Combined Federal/State Filing Program for 2025, so Wisconsin DOR does not receive copies through that channel for that year; Wisconsin tax treatment follows fixed-date IRC conformity (Wis. Stat. 71.01(6)).
Final 2026 form and instructions (instructions dated 18 Feb 2026). Gross proceeds reporting applies to sales on or after 1 Jan 2025 (first forms filed in 2026); basis reporting applies to covered digital assets acquired on or after 1 Jan 2026. On 7 Jan 2026 the IRS posted corrections to the 2025 instructions and excluded Form 1099-DA from the Combined Federal/State Filing Program for tax year 2025.
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Application to Charter National Digital Trust Company, Seattle, Washington (Corporate Decision 1366)
The OCC preliminarily approved a national trust bank for Protego Holdings with crypto-asset custody, customer trading, lending and borrowing, and issuer services platforms.
Wisconsin. Another federal crypto custody charter competing with any Wisconsin state charter or license option.
Preliminary conditional approval 13 Feb 2026.
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De Novo Charter Application and Request for Residency Waivers: Bridge National Trust Bank, New York, New York (Corporate Decision 1365)
The OCC preliminarily approved a national trust bank for Bridge (a Stripe company), which plans to issue U.S. dollar stablecoins and provide related custody services.
Wisconsin. A federal route for a stablecoin issuer that might otherwise rely on state money transmitter licenses, including a Wisconsin license under ch. 217.
Preliminary conditional approval 12 Feb 2026.
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Investments in and Licensing of Permitted Payment Stablecoins Issuers
NCUA proposed the approval and licensing process for payment stablecoin issuers that are subsidiaries of federally insured credit unions, and would limit federally insured credit unions to investing only in NCUA-licensed issuers.
Wisconsin. Applies to Wisconsin federally insured credit unions if they form or invest in a stablecoin issuer; the Office of Credit Unions oversees the state charters.
Proposed. Comment period closed 13 Apr 2026. Not final as of 2 Oct 2026. RIN 3133-AF69. NCUA release 11 Feb 2026.
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Approval Requirements for Issuance of Payment Stablecoins by Subsidiaries of FDIC-Supervised Insured Depository Institutions; Extension of Comment Period
The FDIC extended by 90 days the comment period on its GENIUS application procedures proposal.
Wisconsin. Gave Wisconsin state nonmember banks and their associations more time to comment on the subsidiary application process.
Comment period extended from 17 Feb 2026 to 18 May 2026; now closed. FDIC release 6 Feb 2026.
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Supervisory Condition Letter 2026-01: Anchorage Digital Bank National Association, Sioux Falls, South Dakota, Termination of Operating Agreement
The OCC authorized termination of the 22 Jan 2021 operating agreement imposed on Anchorage Digital Bank, a crypto-focused national trust bank, after finding the bank had complied with each of its provisions.
Wisconsin. Shows the supervisory life cycle of a crypto national trust bank, which Wisconsin policymakers can compare with state trust and money transmitter oversight by DFI.
Issued 9 Feb 2026.
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CFTC Letter No. 26-05: Staff No-Action Position Regarding Digital Assets Accepted as Margin Collateral (reissuance of Letter 25-40)
The Market Participants Division reissued Letter 25-40 unchanged except that a national trust bank may now be a permitted issuer of a payment stablecoin for purposes of the no-action position. After the GENIUS Act effective date, the definition follows GENIUS permitted issuers and compliant foreign issuers.
Wisconsin. The issuer list (state money transmitters, trust companies, national trust banks, then GENIUS permitted issuers) determines whether stablecoins from DFI-licensed or Wisconsin-chartered issuers would qualify as CFTC margin.
In effect; successor to Letter 25-40 (Press Release 9180-26). Issued under Chairman Michael S. Selig, sworn in December 2025.
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Consolidated Appropriations Act, 2026, H.R. 7148 (Division E, Financial Services and General Government Appropriations Act, 2026, title I, sec. 128)
An appropriations provision directs Treasury to report to the appropriations committees, House Financial Services and Senate Banking on the authorities used to set up the Strategic Bitcoin Reserve and U.S. Digital Asset Stockpile, the effect on the Treasury Forfeiture Fund, how the assets appear on the federal balance sheet, and which contractors hold custody.
Wisconsin. Relevant to the WDBC 50-state survey entries on state digital asset reserve bills; no Wisconsin statute is affected.
Law. Pub. L. 119-75, approved 3 Feb 2026. Treasury report due within 90 days (about 4 May 2026). UNVERIFIED: whether Treasury delivered the report.
January 20265 items
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Opening Remarks at Joint SEC-CFTC Harmonization Event: Project Crypto
Chairman Atkins announced that Project Crypto would proceed as a joint SEC and CFTC initiative, designed so the agencies are ready to carry out any market structure legislation Congress passes. The agencies later signed a new memorandum of understanding (11 Mar 2026) and issued the joint interpretation (17 Mar 2026).
Wisconsin. Bears on the Wisconsin Legislative Council 2026 Study Committee on Cryptocurrency’s staking charge and on AB 892; DFI’s 18 Aug 2026 view is that protocol staking is an unregistered security, and Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Remarks by SEC Chairman Atkins at the joint event with CFTC Chairman Michael Selig (rescheduled per Press Release 2026-14). Not a rule.
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Digital Commodity Intermediaries Act (Senate Committee on Agriculture, Nutrition, and Forestry)
The Agriculture Committee’s part of Senate market structure legislation: it would define digital commodities and give the CFTC a spot market registration regime for digital commodity intermediaries, with customer fund segregation, conflict of interest rules, software developer protections and a new CFTC funding stream. The committee says it builds on the House-passed CLARITY Act.
Wisconsin. A CFTC spot regime would cover activity Wisconsin now reaches through DFI money transmission licensing (Wis. Stat. ch. 217) and securities law (ch. 551), raising preemption questions.
Advanced by Senate Agriculture at a business meeting on 29 Jan 2026 (Boozman-Booker discussion draft released 10 Nov 2025; updated text 21 Jan 2026). UNVERIFIED: committee vote count and any bill number assigned.
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Statement on Tokenized Securities
Staff described a taxonomy of tokenized securities: securities tokenized by or for the issuer (where the onchain record is integrated with the master securityholder file) and securities tokenized by unaffiliated third parties (custodial models such as tokenized security entitlements, and synthetic models such as linked securities). A tokenized security remains a security, and the Commission’s September 2026 innovation exemption uses this taxonomy.
Wisconsin. Tokenized securities rest on state commercial law for ownership and transfer; Wisconsin has not enacted UCC Article 12 (see the WDBC model-legislation catalog and 50-state survey).
Joint staff statement of the Divisions of Corporation Finance, Investment Management, and Trading and Markets. Staff views only.
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NCUA’s 2026 Supervisory Priorities (Letter to Credit Unions 26-CU-01)
NCUA’s annual supervisory letter says the agency will continue implementing executive orders and other laws, including the GENIUS Act, while streamlining examinations. It is a passing reference, not digital asset guidance.
Wisconsin. Wisconsin’s federally insured credit unions are examined by NCUA and, for state charters, by the Office of Credit Unions.
Issued January 2026; press release 14 Jan 2026.
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National Bank Chartering
The OCC proposed to amend its chartering rule to clarify that national banks limited to trust company operations may engage in non-fiduciary activities, such as non-fiduciary custody, in addition to fiduciary activities.
Wisconsin. The legal footing for crypto national trust charters that compete with Wisconsin-chartered trust companies and ch. 217 licensees.
Proposed. Comment period closed 11 Feb 2026. Finalized at 91 FR 9977.
December 202515 items
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Request for Information and Comment on Reserve Bank Payment Account Prototype
The Board asked for input on a special purpose Reserve Bank account (a “payment account”) limited to clearing and settling an institution’s payments. It would pay no interest, carry no Fed credit, have balance caps, and get a streamlined review; it would not change who is legally eligible for a Fed account.
Wisconsin. Wisconsin-chartered institutions focused on payments that are legally eligible for Fed services would be among those able to request this narrower account type.
Comment period closed 6 Feb 2026. Followed by the May 2026 payment account proposal. Board release 19 Dec 2025.
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Policy Statement on Section 9(13) of the Federal Reserve Act
The Board withdrew its 2023 policy statement under section 9(13), which had presumptively limited state member banks to activities permissible for national banks, and withdrew from the record the accompanying discussion of specific crypto-asset activities. A new policy statement creates an avenue for insured and uninsured state member banks, and uninsured state bank applicants for membership, to engage in certain innovative activities consistent with safety and soundness.
Wisconsin. A Wisconsin state-chartered bank that is or becomes a Fed member is governed by this statement for novel activities, including crypto-related ones, alongside DFI’s Division of Banking under Wisconsin banking law.
Final. Effective 22 Dec 2025. Board release 17 Dec 2025.
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Approval Requirements for Issuance of Payment Stablecoins by Subsidiaries of FDIC-Supervised Insured Depository Institutions
The FDIC proposed the application process for a state nonmember bank or state savings association seeking approval for a subsidiary to issue payment stablecoins, including review against the GENIUS statutory factors, processing deadlines and an appeal process for denials.
Wisconsin. This is the federal path for Wisconsin state nonmember banks (supervised jointly by the FDIC and DFI’s Division of Banking) to issue a stablecoin through a subsidiary.
Proposed. Comment period extended to 18 May 2026 (91 FR 6138) and closed. Not final as of 2 Oct 2026. RIN 3064-AG20. Board approval 16 Dec 2025.
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Statement on the Custody of Crypto Asset Securities by Broker-Dealers
Staff said it will not object if a broker-dealer deems itself to have ‘physical possession’ of customer crypto asset securities under Rule 15c3-3(b)(1) when it meets listed measures, including direct access and transfer capability and a documented assessment of the underlying distributed ledger and network. The view is limited to that paragraph of Rule 15c3-3.
Wisconsin. Relevant to Wisconsin-based broker-dealers registered with DFI’s Division of Securities under ch. 551 that may carry crypto asset securities for customers.
Division of Trading and Markets staff statement; interim step while the Commission considers broker-dealer custody. Staff views only.
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Division of Trading and Markets: Frequently Asked Questions Relating to Crypto Asset Activities and Distributed Ledger Technology (update of 17 Dec 2025)
The update addresses trading and settlement, including how national securities exchanges and alternative trading systems may offer ‘pairs trading’ of a crypto asset security against a non-security crypto asset, and related Form ATS and ATS-N disclosures. Commissioner Peirce issued a same-day request for information on rules for exchanges and ATSs trading crypto assets.
Wisconsin. Wisconsin’s Uniform Securities Act (ch. 551, administered by DFI’s Division of Securities) has its own registration and exemption rules; Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Staff FAQ (first issued 15 May 2025, pre-period). Questions marked MODIFIED 12/17/2025. Staff views only.
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FDIC Approves Deposit Insurance Application for Erebor Bank, N.A., Columbus, Ohio
The FDIC approved federal deposit insurance for Erebor Bank, whose business model includes virtual currency market participants, subject to conditions such as a 12 percent tier 1 leverage ratio for three years.
Wisconsin. Shows FDIC willingness to insure a bank serving digital asset firms, relevant to Wisconsin banks considering similar customers.
Approved 16 Dec 2025, with conditions.
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Withdrawal of Interpretive Guidance: Retail Commodity Transactions Involving Certain Digital Assets
The Commission withdrew its June 2020 interpretive guidance on when ‘actual delivery’ occurs in retail commodity transactions in virtual currencies, which governed whether leveraged retail crypto transactions had to be on an exchange. The CFTC said the guidance was likely outdated and could conflict with implementing the PWG report.
Wisconsin. The ‘actual delivery’ test affected how leveraged retail crypto offerings reach Wisconsin consumers; its withdrawal leaves no federal staff test in place for DFI to align with under Wis. Stat. 551.608 until replacement guidance issues.
Final. Withdrawal effective 10 Dec 2025; issued by the Commission 11 Dec 2025 (Press Release 9152-25). The 2020 guidance at 85 FR 37734 no longer applies; the CFTC said it would consider whether updated guidance or FAQs are appropriate.
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OCC Announces Conditional Approvals for Five National Trust Bank Charter Applications
The OCC preliminarily approved de novo national trust banks for First National Digital Currency Bank (Circle) and Ripple National Trust Bank, and conditionally approved conversions of BitGo, Fidelity Digital Assets and Paxos from state trust companies to national trust banks. All five center on digital asset custody and related services, and several involve stablecoins.
Wisconsin. National trust charters are a federal alternative to a Wisconsin trust or money transmitter license for crypto custodians and stablecoin firms, and conversions move supervision from state regulators to the OCC.
Approved 12 Dec 2025 (News Release 2025-125): preliminary conditional approvals CA 1356 and CA 1359 (de novo); conditional approvals CA 1353, CA 1355, CA 1358 (conversions).
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The Depository Trust Company (DTCC Tokenization Services, Preliminary Base Version)
Trading and Markets staff said it would not recommend enforcement under Regulation SCI, Exchange Act Section 19(b) and Rule 19b-4, and certain clearing agency standards in connection with DTC operating a pilot securities tokenization service. The relief runs for three years from the date DTC launches the pilot and is limited to the facts in DTC’s request.
Wisconsin. Tokenized securities rest on state commercial law for ownership and transfer; Wisconsin has not enacted UCC Article 12 (see the WDBC model-legislation catalog and 50-state survey).
Staff no-action position, Division of Trading and Markets. Time-limited: three years from launch of the pilot.
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Interpretive Letter 1188: national banks may engage in riskless principal transactions in crypto-assets as part of the business of banking
The OCC confirmed that a national bank may act as riskless principal in crypto-asset trades, buying from one customer while simultaneously selling to another without holding inventory, a role it described as equivalent to a broker acting as agent.
Wisconsin. Another national bank benchmark for Wisconsin state banks; brokering crypto also touches Wisconsin securities law (Wis. Stat. ch. 551) where the asset is a security.
Issued 9 Dec 2025 (News Release 2025-121).
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CFTC Letter No. 25-39: Tokenized Collateral Guidance
Three CFTC divisions set staff expectations for registrants accepting tokenized assets (such as tokenized U.S. Treasuries) as collateral. It covers eligible tokenized assets, legal enforceability, segregation, custody and control (including a perfected security interest), and haircuts that follow the risk approach for the underlying asset.
Wisconsin. Tokenized collateral depends on the legal status of digital records and control, the subject of UCC Article 12, which Wisconsin has not enacted (see WDBC model-legislation catalog).
Staff guidance, in effect. Issued by MPD, DMO and DCR with the digital assets pilot program (Press Release 9146-25). Supplemented by staff FAQs of 20 Mar 2026 and 24 Sep 2026.
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CFTC Letter No. 25-40: Staff No-Action Position Regarding Digital Assets Accepted as Margin Collateral
In response to a request from Coinbase Financial Markets, the Market Participants Division said it would not recommend enforcement against FCMs that accept non-securities digital assets (including bitcoin, ether and payment stablecoins) as customer margin or that deposit their own payment stablecoins into segregated customer accounts, subject to conditions. Conditions include weekly reporting of digital asset holdings to the CFTC for the first three months of reliance.
Wisconsin. Before GENIUS takes effect, the letter’s payment stablecoin definition covers USD stablecoins issued by a state regulated money transmitter or trust company, which can include issuers licensed under Wis. Stat. ch. 217.
Superseded by CFTC Letter No. 26-05 (6 Feb 2026), which reissued it with a revised payment stablecoin definition. Announced as the digital assets pilot program (Press Release 9146-25).
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CFTC Letter No. 25-41: Withdrawal of CFTC Staff Advisory 20-34 on Accepting Virtual Currencies from Customers into Segregation
The Market Participants Division withdrew its 2020 advisory on FCMs accepting virtual currencies into customer segregation, describing it as outdated. The withdrawal accompanied the new tokenized collateral guidance and no-action letter.
Wisconsin. Removes a federal staff constraint on crypto margin at FCMs; Wisconsin custody and transmission rules under ch. 217 are unaffected.
Effective immediately on issuance. Advisory 20-34 (21 Oct 2020) withdrawn in full.
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SEC Announces Agenda and Panelists for Roundtable on Financial Surveillance and Privacy
The Crypto Task Force held a public roundtable on financial surveillance and privacy, including privacy-preserving technologies used with crypto assets. It was the Task Force’s main public roundtable in the period, alongside its written-input program and regional meetings.
Wisconsin. Informational; relevant to WDBC policy library entries on privacy and AML obligations that DFI applies to ch. 217 licensees.
Press Release 2025-138. Crypto Task Force roundtable held 15 Dec 2025 (rescheduled from an earlier date). Informational.
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Acting Chairman Pham Announces First-Ever Listed Spot Crypto Trading on U.S. Regulated Exchanges
The CFTC announced that listed spot crypto products would begin trading on CFTC-registered futures exchanges for the first time, carrying out the August 2025 listed spot initiative. The release also previewed a rulemaking on technical amendments to collateral, margin, clearing, settlement, reporting and recordkeeping rules to accommodate blockchain and tokenization.
Wisconsin. Gives Wisconsin residents a federally registered venue for retail spot crypto, alongside the ch. 217 licensed money transmitters and kiosk operators DFI supervises.
Announced (Press Release 9145-25). The release does not name the exchange. UNVERIFIED: identity of the first DCM to list spot crypto (not stated on cftc.gov).
November 20254 items
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Fuse Crypto Limited (Division of Corporation Finance no-action letter)
Staff said it would not recommend enforcement if Fuse Crypto Limited offers and sells its tokens, as described in its request, without Securities Act registration and without registering them under Exchange Act Section 12(g). The letter relies on counsel’s opinion and the facts presented.
Wisconsin. Wisconsin’s Uniform Securities Act (ch. 551, administered by DFI’s Division of Securities) has its own registration and exemption rules; Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Staff no-action position, Division of Corporation Finance (incoming letter dated 19 Nov 2025). Applies only to the facts presented.
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Interpretive Letter 1186: Authority of national banks to hold crypto-assets as principal and pay crypto-asset network fees as incidental to a permissible banking activity
The OCC confirmed that a national bank may pay blockchain network (“gas”) fees to support permissible activities and may hold, as principal, the crypto-assets it reasonably expects to need for those fees, and may hold crypto-assets as principal to test permissible crypto platforms. Earlier 2025 letters had reaffirmed crypto custody, holding stablecoin reserve deposits and distributed ledger payments as permissible (IL 1183) and clarified custody authority (IL 1184).
Wisconsin. Sets the national bank benchmark that Wisconsin state banks may point to when seeking similar authority from DFI.
Issued 18 Nov 2025 (News Release 2025-108). Builds on IL 1183 (7 Mar 2025) and IL 1184 (7 May 2025), both pre-period.
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The SEC’s Approach to Digital Assets: Inside “Project Crypto”
Chairman Atkins outlined a ‘token taxonomy’ anchored in the Howey investment contract test, and the view that an investment contract can come to an end, so a token sold in one can later trade without being a security. He said staff were drafting rule amendments and that the approach was meant to complement federal market structure legislation.
Wisconsin. Bears on the Wisconsin Legislative Council 2026 Study Committee on Cryptocurrency’s staking charge and on AB 892; DFI’s 18 Aug 2026 view is that protocol staking is an unregistered security, and Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Speech by Chairman Atkins. Not a rule; its approach was later adopted in Commission Release 33-11412 (17 Mar 2026).
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Rev. Proc. 2025-31 (safe harbor for investment trusts and grantor trusts that stake digital assets)
Gives a safe harbor under which a trust holding one type of digital asset (for example, a spot crypto exchange-traded product) can stake those assets through custodians and staking providers without losing its status as an investment trust and grantor trust. The trust must meet listed conditions, including liquidity reserves, indemnity against slashing and at least quarterly distribution or sale of rewards. It does not address when staking rewards are taxed.
Wisconsin. Bears on the staking question before the Wisconsin Legislative Council crypto study committee (AB 892), though that charge is about securities law; on the tax side Wisconsin follows the IRC only as of its fixed conformity date (Wis. Stat. 71.01(6)).
In effect for tax years ending on or after 10 Nov 2025. Existing trusts could amend their trust agreements during the nine months beginning 10 Nov 2025 (window ended about 10 Aug 2026). Published in I.R.B. 2025-48 (24 Nov 2025).
October 20255 items
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Notice 2025-49: Additional Interim Guidance for the Application of the Corporate Alternative Minimum Tax
Section 5 lets a corporation subject to the corporate alternative minimum tax (CAMT) disregard, when computing adjusted financial statement income, gains and losses on items measured at fair value that are not realized for regular tax purposes. The notice names holdings of digital assets as an example, so large corporations carrying crypto at fair value can generally keep unrealized gains out of CAMT.
Wisconsin. Wisconsin has no corporate AMT and conforms to the IRC as of a fixed date (Wis. Stat. 71.01(6)), so this matters mainly to large companies with Wisconsin operations at the federal level.
Interim guidance; taxpayers may rely on it pending revised proposed CAMT regulations. Published in I.R.B. 2025-44 (27 Oct 2025). UNVERIFIED: earlier IRS release date.
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Imposition of Special Measure Regarding Huione Group, as a Foreign Financial Institution of Primary Money Laundering Concern
Under section 311 of the USA PATRIOT Act, FinCEN barred U.S. financial institutions from opening or keeping correspondent accounts for Cambodia-based Huione Group. FinCEN found it to be a primary money laundering concern for laundering proceeds of North Korean cyber heists and crypto investment scams. The rule describes Huione’s crypto businesses, including the Haowang/Huione Guarantee marketplace and its USDH stablecoin, which the rule says cannot be frozen.
Wisconsin. Covered financial institutions, including Wisconsin state banks and credit unions, must apply the special due diligence on correspondent accounts.
Final. Effective 17 Nov 2025. RIN 1506-AB68; codified at 31 CFR 1010.664. Proposed 1 May 2025 (pre-period).
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Application to charter Erebor Bank, National Association, Columbus, Ohio (Conditional Approval 1348)
The OCC preliminarily approved a de novo full-service national bank whose business includes serving technology and virtual currency firms. The Comptroller said the decision shows the OCC does not impose blanket barriers on banks that engage in permissible digital asset activities.
Wisconsin. An example of a federally chartered, insured bank serving digital asset firms that competes with Wisconsin state banks chartered by DFI.
Preliminary conditional approval 15 Oct 2025 (News Release 2025-101). FDIC approved deposit insurance 16 Dec 2025.
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U.S. and U.K. Take Largest Action Ever Targeting Cybercriminal Networks in Southeast Asia
OFAC designated the Cambodia-based Prince Group as a transnational criminal organization, along with dozens of affiliated people and companies, as part of a joint U.S. and U.K. action against scam-compound networks that run digital asset investment fraud. The SDN entries include bitcoin addresses. The same day, FinCEN finalized its section 311 action against Huione Group (see the 16 Oct 2025 FR entry).
Wisconsin. Scam-center networks target U.S. residents through crypto transfers and kiosks, so these designations shape the sanctions screening Wisconsin money transmitters (ch. 217) must run.
Designations effective 14 Oct 2025 (OFAC recent action 20251014; Treasury press release sb0278); TCO General License 1 authorized a wind-down. UNVERIFIED: the press release text (blocked by home.treasury.gov during this research) and the details of the related Justice Department bitcoin forfeiture.
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GENIUS Act Implementation
This is a short procedural notice that extended the comment period on Treasury’s GENIUS Act ANPRM (90 FR 45159) by 15 days, to 4 Nov 2025. It changed nothing else in the ANPRM.
Wisconsin. Procedural only; it set the final date for comment on the ANPRM that shaped the state-regime rules a Wisconsin framework will be measured against.
Comment period extension notice for the 19 Sep 2025 ANPRM: deadline moved by 15 days from 20 Oct 2025 to 4 Nov 2025. Same docket TREAS-DO-2025-0037 and RIN 1505-ZA10. Not a correction or new proposal.
September 20258 items
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Simpson Thacher & Bartlett LLP (Division of Investment Management no-action letter on State Trust Companies as crypto asset custodians)
Staff said it would not recommend enforcement against registered investment advisers or regulated funds that treat a qualifying state-chartered trust company as a ‘bank’ (and therefore a permitted custodian) for crypto assets and related cash, under the Advisers Act custody rule and the Investment Company Act custody provisions. The letter sets conditions on the trust company’s authorization, supervision and safeguarding practices.
Wisconsin. Relevant to Wisconsin state banks and trust companies supervised by DFI’s Division of Banking that may custody crypto assets for advisers, funds or broker-dealers.
Staff no-action position, Office of Chief Counsel, Division of Investment Management. Applies subject to the conditions in the letter. The 1 Oct 2026 custody proposal would address state trust companies by rule.
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DoubleZero (Division of Corporation Finance no-action letter)
Staff said it would not recommend enforcement if DoubleZero’s programmatic transfers of its 2Z token to participants in its decentralized physical infrastructure network (DePIN) are not registered under Securities Act Section 5, and if 2Z is not registered as a class of equity securities under Exchange Act Section 12(g). It was the first in-period no-action letter for a network token.
Wisconsin. Wisconsin’s Uniform Securities Act (ch. 551, administered by DFI’s Division of Securities) has its own registration and exemption rules; Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Staff no-action position, Office of Chief Counsel, Division of Corporation Finance. Applies only to the facts presented.
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Acting Chairman Pham Launches Tokenized Collateral and Stablecoins Initiative
The CFTC opened an initiative on using tokenized collateral, including stablecoins, as margin in derivatives markets, citing the GENIUS Act and earlier Global Markets Advisory Committee work. Stakeholders were invited to submit input by 20 Oct 2025.
Wisconsin. Federal acceptance of payment stablecoins as derivatives margin bears on the practical use of any Wisconsin state payment stablecoin framework under GENIUS (WDBC discussion draft; SCRC state certification due by 18 Jan 2028).
Input period closed 20 Oct 2025. Implemented through Staff Letters 25-39, 25-40 and 25-41 on 8 Dec 2025.
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Self-Regulatory Organizations; The Nasdaq Stock Market LLC; Cboe BZX Exchange, Inc.; NYSE Arca, Inc.; Order Granting Accelerated Approval of Proposed Rule Changes, as Modified by Amendments Thereto, To Adopt Generic Listing Standards for Commodity-Based Trust Shares
The Commission approved generic listing standards at three exchanges so that trusts holding spot commodities, including digital assets, can list without a separate Section 19(b) rule filing if they meet set criteria, such as the underlying commodity trading on a market with surveillance sharing or having a regulated futures market for at least six months. The same day the Commission approved the Grayscale Digital Large Cap Fund (Release No. 34-103996, 90 FR 45440).
Wisconsin. Widens the range of exchange-listed crypto products available to Wisconsin investors; listed ETP shares are federal covered securities, so DFI does not register them but keeps antifraud authority under ch. 551.
Approved by the Commission 17 Sep 2025 (Release No. 34-103995; Press Release 2025-121); published in FR 22 Sep 2025. In effect.
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Regulatory Flexibility Agenda (Spring 2025)
The Chairman’s Spring 2025 agenda listed a Corporation Finance proposed rule titled ‘Crypto Assets’ (RIN 3235-AN38) on the offer and sale of crypto assets, including possible exemptions and safe harbors, with an NPRM target of April 2026. Chairman Atkins said the agenda reflected a priority on rules for the issuance, custody and trading of crypto assets; RIN 3235-AN38 became Regulation Crypto Assets (Aug 2026).
Wisconsin. Wisconsin’s Uniform Securities Act (ch. 551, administered by DFI’s Division of Securities) has its own registration and exemption rules; Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Published 22 Sep 2025 (Release No. 33-11379). Chairman’s statement on the agenda issued 4 Sep 2025. Informational.
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GENIUS Act Implementation
Treasury’s first GENIUS Act rulemaking notice asked broad questions about the rules Treasury itself must write: regulatory clarity, the limits on who may issue and market payment stablecoins, Bank Secrecy Act and sanctions obligations, how state oversight is balanced against federal oversight, comparable foreign regimes, and tax issues. It proposed no rule text.
Wisconsin. Opened the federal record on the state-regime question that a Wisconsin GENIUS state payment stablecoin framework (WDBC discussion draft) must answer before SCRC certification, due by 18 Jan 2028.
Closed. Comments originally due 20 Oct 2025, extended to 4 Nov 2025 (90 FR 47251). Docket TREAS-DO-2025-0037, RIN 1505-ZA10. Followed by the part 1521, 1522 and 1523 rulemakings.
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SEC and CFTC Issue Joint Statement on Regulatory Harmonization Efforts; Will Co-Host Roundtable Sept. 29
The two agency heads said the agencies should consider harmonizing product and venue definitions, streamlining reporting and data standards, aligning capital and margin frameworks, and standing up coordinated innovation exemptions under existing authority. They announced a joint public roundtable on harmonization for 29 Sep 2025.
Wisconsin. Bears on the Wisconsin Legislative Council 2026 Study Committee on Cryptocurrency’s staking charge and on AB 892; DFI’s 18 Aug 2026 view is that protocol staking is an unregistered security, and Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Joint statement by SEC Chairman Atkins and CFTC Acting Chairman Pham (Press Release 2025-112). Joint roundtable held 29 Sep 2025.
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Joint Staff Statement (Project Crypto-Crypto Sprint)
Staff of both agencies stated their view that current law does not prohibit SEC-registered national securities exchanges, CFTC-registered DCMs or registered FBOTs from facilitating trading of certain leveraged, margined or financed spot crypto asset products. It invited filings and listed considerations on margin, clearing, custody, surveillance and public trade data.
Wisconsin. Wis. Stat. 551.608 points DFI toward uniformity with SEC and CFTC interpretations, and this joint view shapes where Wisconsin residents can trade spot crypto under federal supervision.
Staff statement, in effect. Issued by the SEC Division of Trading and Markets with the CFTC Divisions of Market Oversight and Clearing and Risk (CFTC Press Release 9112-25). Also announced in SEC Press Release 2025-110.
August 202512 items
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CFTC Letter No. 25-27: Division of Market Oversight advisory on the foreign board of trade (FBOT) registration framework
The Division of Market Oversight reaffirmed the FBOT registration path for non-U.S. exchanges that want to give persons in the U.S. direct access to their platforms, and stated it applies to all asset classes including digital assets. The advisory was presented as a route for offshore crypto trading venues to serve U.S. customers under CFTC registration rather than designating as a DCM.
Wisconsin. Offshore crypto venues registering as FBOTs would reach Wisconsin residents under CFTC oversight; DFI’s ch. 217 money transmission licensing still applies to any related custody or transmission of value.
Staff advisory, in effect (Press Release 9111-25).
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Request for Comment on Innovative Methods To Detect Illicit Activity Involving Digital Assets
Treasury asked the public how regulated financial institutions use, or could use, newer tools to detect money laundering and other illicit activity involving digital assets, including application programming interfaces, artificial intelligence, digital identity verification and blockchain monitoring. GENIUS Act sec. 9 required this comment period, and later sections direct Treasury research, a report to Congress and FinCEN guidance and rulemaking (within 3 years of enactment) based on the results.
Wisconsin. Feeds future FinCEN standards for transaction monitoring that would reach Wisconsin money transmitters licensed by DFI under Wis. Stat. ch. 217, including crypto kiosk operators licensed under s. 217.12.
Closed. Comments were due 17 Oct 2025. Issued under GENIUS Act sec. 9(a) (12 U.S.C. 5908(a)). FR Doc. 2025-15697; Treasury press release sb0228 the same day.
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Federal Reserve Board announces it will sunset its novel activities supervision program and return to monitoring banks’ novel activities through the normal supervisory process
The Board ended the separate program it created in 2023 to supervise crypto and fintech activities at the banks it oversees. Those activities are now supervised through the ordinary examination process, and the 2023 supervisory letter that set up the program was rescinded.
Wisconsin. The Fed supervises Wisconsin state member banks alongside DFI’s Division of Banking, so crypto or fintech work at those banks is now examined in the normal cycle rather than through a separate federal program.
Effective on announcement. Rescinded the 2023 supervisory letter (SR 23-7) that created the program.
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Treasury Sanctions Cryptocurrency Exchange and Network Enabling Sanctions Evasion and Cyber Criminals
OFAC re-designated the Russia-linked crypto exchange Garantex (Garantex Europe OU), which it first sanctioned in 2022, together with its successor exchange Grinex and related executives and companies, under its cyber-related sanctions program. The SDN list entries include specific crypto wallet addresses, and U.S. persons, including crypto businesses, may not deal with them.
Wisconsin. Sanctions screening against listed wallet addresses applies to every Wisconsin-licensed money transmitter and crypto kiosk operator (Wis. Stat. ch. 217; kiosks under s. 217.12).
Designations effective 14 Aug 2025 (OFAC recent action 20250814; Treasury press release sb0225). SDN entries list digital currency addresses.
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Democratizing Access to Alternative Assets for 401(k) Investors
The order directs the Department of Labor to re-examine its guidance on alternative assets in 401(k) and other defined-contribution plans, including actively managed vehicles that invest in digital assets, and to clarify within 180 days how fiduciaries should weigh them. It also asks the SEC to make it easier for plan participants to access alternative assets.
Wisconsin. Affects private-sector 401(k) plans of Wisconsin employers; ERISA preempts state law here, so the state’s role is limited.
EO 14330, signed 7 Aug 2025, published 12 Aug 2025. Implemented in part by the DOL proposed rule at 91 FR 16088 (31 Mar 2026).
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Guaranteeing Fair Banking for All Americans
The order directs the federal banking regulators to remove ‘reputational risk’ and similar concepts from their guidance and exam materials. It also directs reviews of ‘politicized or unlawful debanking’, meaning denial of services because of political or religious beliefs or lawful business activities, with remedial steps due within 180 days. The order text does not name digital assets, but the definition reaches lawful crypto businesses.
Wisconsin. Federal supervisory changes under this order reach Wisconsin state banks and credit unions jointly supervised with the FDIC, the Federal Reserve or NCUA.
EO 14331, signed 7 Aug 2025, published 12 Aug 2025. Related federal action includes the OCC/FDIC final rule removing reputation risk (91 FR 18279, 10 Apr 2026).
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Statement on Certain Liquid Staking Activities
Staff said that liquid staking, where a provider stakes deposited crypto assets and issues one-for-one ‘staking receipt tokens’, does not involve the offer and sale of securities when the deposited assets are not themselves securities or subject to an investment contract. Staff also said the staking receipt tokens are not securities in those circumstances.
Wisconsin. Bears on the Wisconsin Legislative Council 2026 Study Committee on Cryptocurrency’s staking charge and on AB 892; DFI’s 18 Aug 2026 view is that protocol staking is an unregistered security, and Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Division of Corporation Finance staff statement (Press Release 2025-104). Superseded on these topics by Commission Release 33-11412 (17 Mar 2026), which adopted a Commission-level view on liquid staking and staking receipt tokens.
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Acting Chairman Pham Launches Listed Spot Crypto Trading Initiative
The CFTC invited public input on how leveraged, margined or financed retail spot crypto transactions could be listed on CFTC-registered futures exchanges (designated contract markets) under existing law, including CEA section 2(c)(2)(D) and Part 40. It was the first initiative under the crypto sprint.
Wisconsin. Retail crypto trading on federally registered exchanges sits beside, not inside, Wisconsin’s money transmission regime under Wis. Stat. ch. 217, which DFI administers, including kiosk licensing under s. 217.12 (2025 Wis. Act 226).
Input period closed 18 Aug 2025. Led to first listed spot crypto trading on a DCM, announced 4 Dec 2025 (Press Release 9145-25).
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FinCEN Notice on the Use of Convertible Virtual Currency Kiosks for Scam Payments and Other Illicit Activity (FIN-2025-NTC1)
FinCEN urged financial institutions to watch for and report suspicious activity involving crypto kiosks (crypto ATMs). The notice describes how scammers send victims to kiosks and how drug trafficking groups use them to move cash, lists red flags, and reminds kiosk operators of their Bank Secrecy Act duties as money services businesses. It cites FBI data showing 10,956 kiosk complaints in 2024 with about $246.7 million in reported losses.
Wisconsin. Bears directly on crypto kiosk operators, which Wisconsin licenses under Wis. Stat. 217.12 (created by 2025 Wis. Act 226: license required, $1,000 daily limit, posted fraud warning, refunds).
Issued 4 Aug 2025. SAR key term FIN-2025-CVCKIOSK. Supplements FinCEN advisory FIN-2019-A003.
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Acting Chairman Pham Announces CFTC Crypto Sprint
The CFTC’s acting chairman launched a ‘crypto sprint’ to carry out the CFTC recommendations in the President’s Working Group on Digital Asset Markets report of July 2025, in coordination with the SEC’s Project Crypto. On 21 Aug 2025 the CFTC opened public input on every PWG recommendation addressed to it. The sprint became the umbrella for the listed spot crypto, tokenized collateral and related staff actions that followed.
Wisconsin. Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC practice, so the crypto sprint outputs are part of the federal baseline the Legislative Council Study Committee on Cryptocurrency is working against.
Announced (Press Release 9104-25). A follow-on ‘next crypto sprint’ (Press Release 9109-25, 21 Aug 2025) invited input on all PWG report recommendations for the CFTC by 20 Oct 2025; that window is closed.
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Self-Regulatory Organizations; The Nasdaq Stock Market LLC; Cboe BZX Exchange, Inc.; NYSE Arca, Inc.; Order Granting Accelerated Approval of Proposed Rule Changes, as Modified by Amendments Thereto, To Amend Certain Bitcoin and Ether-Based Commodity-Based Trust Shares (in-kind creations and redemptions)
The Commission approved exchange rule changes letting spot bitcoin and ether exchange-traded products create and redeem shares in kind (in the underlying crypto asset) instead of only in cash, matching other commodity-based ETPs. The same day it approved related orders, including a mixed bitcoin and ether ETP and options on certain bitcoin ETPs.
Wisconsin. Affects how crypto ETPs held by Wisconsin investors and advisers operate; no change to Wisconsin law (exchange-listed ETP shares are federal covered securities that DFI does not register under ch. 551).
Approved by the Commission 29 Jul 2025 (Release No. 34-103571); published in FR 1 Aug 2025. In effect.
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On the Road: SEC Crypto Task Force to Host a Series of Roundtables Across the U.S.
The Crypto Task Force led by Commissioner Hester Peirce announced a series of in-person meetings across the U.S. (ten dates, Aug to Dec 2025), aimed at crypto projects with 10 or fewer employees that are under two years old. It complements the Task Force’s written-input program and its spring 2025 Washington roundtables.
Wisconsin. The schedule included Chicago (15 Sep 2025) and Ann Arbor (5 Dec 2025), the nearest stops for Wisconsin projects; the Task Force also accepts written input.
Press Release 2025-102. Outreach meetings held Aug to Dec 2025. Informational.
July 20254 items
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American Leadership in the Digital Finance Revolution
Chairman Atkins announced Project Crypto, a Commission-wide initiative, and said he had directed staff to draft rules for crypto asset distributions, custody and trading for public comment. He also described a planned ‘innovation exemption’ and interim use of interpretive and exemptive authority; later actions in this list (the March 2026 interpretation, Regulation Crypto Assets, the September 2026 innovation exemption and the October 2026 custody proposal) follow from it.
Wisconsin. Wisconsin’s Uniform Securities Act (ch. 551, administered by DFI’s Division of Securities) has its own registration and exemption rules; Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Speech by Chairman Paul S. Atkins launching ‘Project Crypto’. Not a rule.
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Strengthening American Leadership in Digital Financial Technology
The Working Group’s report sets out legislative and regulatory recommendations on digital asset market structure, banking, stablecoins and payments, illicit finance and taxation. It asks Congress to give the CFTC authority over spot markets for non-security digital assets, asks the SEC and CFTC to use existing authority to enable trading, and asks the banking agencies to clarify which digital asset activities banks may conduct.
Wisconsin. Its banking, tax and AML recommendations frame later federal rules that reach DFI-chartered banks, ch. 217 money transmitters and, through fixed-date conformity (Wis. Stat. 71.01(6)), Wisconsin income tax.
Released 30 Jul 2025 by the President’s Working Group on Digital Asset Markets under EO 14178 (White House fact sheet dated 30 Jul 2025).
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Comptroller Issues Statement on Enactment of GENIUS Act
Comptroller Gould said the OCC would move quickly to implement the GENIUS Act, which expands OCC authority to include nonbank payment stablecoin issuers.
Wisconsin. Signals that the OCC becomes the federal licensor for nonbank issuers that do not use a state-qualified path such as a future Wisconsin framework.
Issued 18 Jul 2025 (News Release 2025-73).
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Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), S. 1582
Creates the federal framework for payment stablecoins: only permitted issuers (subsidiaries of insured depository institutions, federal qualified issuers licensed by the OCC, or state qualified issuers) may issue them, with 1:1 reserves, monthly disclosures and AML duties. Issuers with $10 billion or less outstanding may choose state regulation if the state regime is certified as substantially similar through the Stablecoin Certification Review Committee.
Wisconsin. Sets the path for a Wisconsin state payment stablecoin framework (WDBC has a discussion draft); state certification by the SCRC is due by 18 Jan 2028, with DFI the likely state regulator alongside its Wis. Stat. ch. 217 role.
Law. Pub. L. 119-27, signed 18 Jul 2025. Senate passed 68-30 (17 Jun 2025, Record Vote 318); House passed 308-122 (17 Jul 2025, Roll 200). Takes effect on the earlier of 18 months after enactment (18 Jan 2027) or 120 days after final implementing regulations.
Before the GENIUS Act: context9 items
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Digital Asset Market Clarity Act of 2025 (CLARITY Act), H.R. 3633: House passage
The House bill would divide digital asset oversight between the SEC and CFTC, giving the CFTC a new spot market regime for “digital commodities” and creating a path for tokens on mature blockchains to leave securities treatment. It addresses protocol staking and other blockchain activities and would preempt some state securities registration for digital commodities.
Wisconsin. Would shift jurisdiction away from state securities regulators (DFI under Wis. Stat. ch. 551) through federal preemption, and its staking language bears on the Wisconsin crypto study committee’s staking charge and DFI’s 18 Aug 2026 view.
Pre-period context. Passed House 294-134 (Roll 199) on 17 Jul 2025. Received in the Senate and referred to Banking 18 Sep 2025. Not enacted; see the later Senate records.
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Anti-CBDC Surveillance State Act, H.R. 1919
Would bar the Federal Reserve from issuing a central bank digital currency, directly or through intermediaries, and from using one for monetary policy, without authorization from Congress.
Wisconsin. No direct state role; context for Wisconsin’s payment stablecoin framework work under GENIUS, since a CBDC ban leaves private stablecoins as the dollar digital payment instrument.
Pre-period context. Passed House 219-210 (Roll 201) on 17 Jul 2025, its latest action; no separate Senate action. Not included in the FY2026 NDAA (Pub. L. 119-60, 18 Dec 2025, has no CBDC provision). Its text was also carried as Title VI of House-passed H.R. 3633, but the Senate Banking substitute (1 Jun 2026) drops it. A time-limited CBDC ban was enacted in Pub. L. 119-101 (see that record).
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Gross Proceeds Reporting by Brokers That Regularly Provide Services Effectuating Digital Asset Sales (Revocation of T.D. 10021)
Treasury and the IRS removed the DeFi broker amendments from the Code of Federal Regulations to carry out Pub. L. 119-5. The custodial broker rules in T.D. 10000 (July 2024) are not affected.
Wisconsin. Context only: the revoked rule never took effect, and Wisconsin tax law follows the IRC as of a fixed date under Wis. Stat. 71.01(6).
Pre-period context. Final rule (CRA revocation), effective 11 Jul 2025. Removes the T.D. 10021 amendments and restores the prior section 6045 regulation text.
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Notice 2025-33: Extension and Modification of Transitional Relief Under Sections 3403, 3406, 6721, 6722, 6651, and 6656 with Respect to the Reporting of Information and Backup Withholding on Digital Assets by Brokers under Section 6045
Extends the Notice 2024-56 relief: no backup withholding on digital asset sales in 2025 and 2026, and in 2027 none for customers whose name and TIN pass IRS TIN matching or for certain preexisting accounts with non-U.S. addresses. For 2025 sales reported in 2026, the IRS will not impose filing and furnishing penalties on brokers that make good faith efforts to file Form 1099-DA correctly and on time.
Wisconsin. Explains why Wisconsin residents first received Form 1099-DA in early 2026 without backup withholding; any state treatment follows federal law only as of Wisconsin’s fixed IRC conformity date (Wis. Stat. 71.01(6)).
Pre-period context, still in force. Issued 12 Jun 2025 (IR-2025-67); published in I.R.B. 2025-28.
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Statement on Certain Protocol Staking Activities
Corporation Finance staff said that protocol staking (solo staking, self-custodial staking with a third party, and certain custodial staking) does not involve the offer and sale of securities. It is the staff baseline that the August 2025 liquid staking statement and the March 2026 Commission interpretation built on.
Wisconsin. Bears on the Wisconsin Legislative Council 2026 Study Committee on Cryptocurrency’s staking charge and on AB 892; DFI’s 18 Aug 2026 view is that protocol staking is an unregistered security, and Wis. Stat. 551.608 directs DFI toward uniformity with SEC and CFTC administration.
Pre-period context. Division of Corporation Finance staff statement. Superseded on these topics by Commission Release 33-11412 (17 Mar 2026).
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Compliance Assistance Release No. 2025-01, 401(k) Plan Investments in “Cryptocurrencies”
The Department of Labor withdrew its 2022 guidance telling 401(k) fiduciaries to use ‘extreme care’ before offering crypto options. It returned to a neutral position that neither endorses nor disapproves of including cryptocurrency on a plan menu.
Wisconsin. Context for private-sector Wisconsin employer plans; ERISA governs, not state law.
Pre-period context. Rescinded Compliance Assistance Release 2022-01 (‘extreme care’ guidance on crypto in 401(k) menus). Date and effect confirmed through DOL’s own citation in 91 FR 16088; dol.gov returned 403, so the document itself was not downloaded.
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Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to “Gross Proceeds Reporting by Brokers That Regularly Provide Services Effectuating Digital Asset Sales” (H.J.Res. 25)
Congress used the Congressional Review Act to cancel the IRS final rule that would have treated certain decentralized finance (DeFi) front-end service providers as brokers required to file Form 1099-DA. Under the CRA, the IRS may not reissue a substantially similar rule without new authority from Congress.
Wisconsin. Context for the 50-state survey: federal broker reporting now reaches only custodial brokers, and any Wisconsin tax effect still runs through fixed-date IRC conformity under Wis. Stat. 71.01(6).
Pre-period context. Enacted as Pub. L. 119-5 on 10 Apr 2025 (House passed 26 Mar 2025). The DeFi broker rule (T.D. 10021) has no force or effect (confirmed in 90 FR 30825). UNVERIFIED: exact official title wording of H.J.Res. 25 (congress.gov API rate-limited).
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Statement on Stablecoins
Corporation Finance staff said that ‘Covered Stablecoins’ (USD-pegged, redeemable one-for-one, and backed by a reserve of low-risk, readily liquid assets at least equal to redemption value) are not securities, so their offers and sales need not be registered. It predates the GENIUS Act and is listed here as background. Related pre-period staff statements: meme coins (27 Feb 2025), proof-of-work mining (20 Mar 2025), protocol staking (29 May 2025).
Wisconsin. Relevant to a Wisconsin state payment stablecoin framework under GENIUS (WDBC has a discussion draft; SCRC state certification due by 18 Jan 2028) and to DFI’s money transmission licensing under Wis. Stat. ch. 217 (CSBS MTMA, 2023 Wis. Act 267).
Pre-period context. Division of Corporation Finance staff statement. Commission views in Release 33-11412 (17 Mar 2026) supersede prior staff statements on these topics.
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BITCOIN Act of 2025, S. 954
Would set up a statutory Strategic Bitcoin Reserve and direct federal bitcoin purchases. It has had no committee action; Congress instead asked Treasury for a report on the existing reserve in Pub. L. 119-75.
Wisconsin. Context for the WDBC 50-state survey of state bitcoin reserve bills; no Wisconsin statute is affected.
Pre-period context. Referred to Senate Banking 11 Mar 2025; no further action as of 2 Oct 2026.
Key dates ahead
- 19 Oct 2026Treasury issuance, offer and sale comments close
- 20 Oct 2026SEC Regulation Crypto Assets comments close
- 3 Nov 2026SEC transfer agent comments close
- 30 Nov 2026Comments close on the state certification rule and the Fed’s two GENIUS proposals
- 31 Dec 2026IRS lot-identification relief ends; last year of full backup-withholding relief on digital asset sales
- 18 Jan 2027The GENIUS Act takes effect. No final rule had issued by 2 October, so the 18-month date governs.
- 18 Jan 2028State certification deadline. Any form of certification, even a conditional one, meets it.
- 18 Jul 2028Sale bar. Providers may sell only stablecoins from permitted or qualifying foreign issuers.
- 31 Dec 2030The statutory bar on a Fed CBDC expires
- 17 Sep 2031The SEC’s innovation exemption for tokenized securities venues expires
Sources: the Federal Register, agency releases and congress.gov, linked on each entry. Excluded: commissioner-only statements, enforcement actions, routine product filings and prediction-market actions. This page reports and explains; it is not legal advice. Corrections are welcome at team@wdbc.io.
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