U.S. regulated-track stablecoins earn income on their reserves, and the issuer is not the party that takes the largest share of it. My analysis puts that reserve income at $3.42 billion a year at current Treasury bill rates, an annual run-rate rather than booked revenue. Of it, $1.47 billion to $1.86 billion goes to the distributors that hold the customer rather than to the issuer. That is more than Circle, the largest regulated-track issuer, retains.

On September 24, 2026, the Federal Reserve proposed reserve, capital and application rules for the stablecoin issuers it supervises under the GENIUS Act. It was the last federal banking agency to propose its rules before the Act takes effect on January 18, 2027; the FDIC, NCUA and OCC had made their proposals between December 2025 and June 2026. Circle’s national trust bank received final OCC approval in July 2026.

Capital is the small cost. The Federal Reserve’s proposed operational-risk capital charge costs a Board-supervised issuer about 20 basis points of balance a year. That is a small fraction of what Circle pays its distributors.

For a bank weighing a coin of its own, distribution and rates decide which route pays. Whether its coin out-earns the average deposit turns on the Treasury bill yield and on whether the bank owns its distribution or buys it. The report prices the routes a bank can take against a nonbank issuer that rents its distribution, and gives the bill-rate break-even for each route.

In the base case, distributor-commissioned, issuer-direct and bank-owned coins are forecast to gain share of regulated-track balances by 2031, while USDC, placed through rented distribution, keeps the majority. Two open decisions could reset these numbers. If the OCC and the Federal Reserve finalise their third-party yield presumption as proposed, and it reaches rewards-paying distributors, it could put at issue the USDC rewards Coinbase pays holders. Tether’s USDT, held outside the regulated perimeter, would change the market’s size materially if it entered.

The full analysis, with the market’s size, its conservative, base and optimistic scenarios to 2031, a scenario matrix that sizes the market with USDT inside the perimeter, and the company profiles, is in Policy2050’s report on the U.S. Regulated Payment Stablecoin Market.