The Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) is a first-of-its-kind regulatory framework for “payment stablecoins” and the entities that issue them. For companies honing their stablecoin issuance strategy, the GENIUS Act presents an important decision point: how to enter the market compliantly, at what scale, and under which regulatory regime. We summarize three forward-looking payment stablecoin issuance paths available under the GENIUS Act, each allowing issuers to remain outside the maximalist regulatory regime that applies to commercial banks.

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