Overview

• The advance notice of proposed rulemaking opened Sept. 18–19 and the public comment period closes Oct. 20, 2025.
• Treasury’s questions span reserve custody, issuer prohibitions, Bank Secrecy Act and sanctions obligations, tax treatment, the state‑federal balance, and comparability with foreign regimes.
• Officials explicitly seek views on potential “indirect” rewards that could work around the law’s ban on issuer‑paid interest.
• The consultation builds on last month’s request for input on technologies to detect illicit activity in digital assets.
• Statutory milestones require final rules by July 18, 2026, the law’s effective date on Jan. 18, 2027, and full compliance by July 18, 2028, prompting issuers and banks to prepare while political leaders press for rapid, market‑friendly implementation.