Dual-track regulation takes shape: In-depth analysis of the CLARITY Act, Reg Crypto, and FDIC rules

In April 2026, the U.S. cryptocurrency regulatory landscape entered the most intensive policy-advancement period in recent years. Senate negotiators reached a compromise on the stablecoin yield provisions in the CLARITY Act; the SEC officially submitted the “Reg Crypto” framework to the White House Office of Information and Regulatory Affairs for review; the FDIC issued bank stablecoin guidance based on the GENIUS Act; and the Treasury Department also advanced rulemaking on anti-money laundering at the same time. With four regulatory axes moving forward in parallel, a dual-track U.S. cryptocurrency regulatory system—jointly formed by congressional legislation, agency rules, and cross-department coordination—is accelerating into shape.

Legislative Breakthrough: What the Compromise Plan in the CLARITY Act Means

The compromise reached by the Senate Banking Committee on the stablecoin yield issue has broken the CLARITY Act’s months-long deadlock. The core logic of the final plan is clear: it allows reward programs based on user stablecoin activity, but it does not allow balance yields to be earned solely for holding stablecoins. This distinction balances the banking industry’s concerns about deposit outflows with the crypto industry’s demand for room to innovate.

The revised text is currently circulating among industry stakeholders for review, and the Senate Banking Committee is expected to move the review and voting forward by the end of April. Data from the prediction market Polymarket shows that traders believe the probability that the CLARITY Act will be signed into law in 2026 is about 63%, down from the prior peak, reflecting the market’s cautious stance toward the details of the compromise plan.

The legislative significance of the bill is that it will establish the first comprehensive market-structure regulatory framework for U.S. digital assets, clarify the jurisdictional boundaries between the SEC and CFTC, and put an end to the long-standing regulatory ambiguity that has plagued the industry.

SEC New Rules: Core Mechanisms and Exemption Design of the Reg Crypto Framework

The SEC’s “Reg Crypto” proposal has been officially submitted to the White House Office of Information and Regulatory Affairs for review—an essential step before the rule is published and the public is invited to comment. According to the explanation by SEC Chair Paul Atkins, the proposal aims to establish “a comprehensive regulatory framework for securities related to crypto assets.”

The framework includes three core exemption mechanisms: the startup exemption, which allows crypto projects to raise funds within four years under specified disclosure requirements; the fundraising exemption, which sets structured disclosure obligations for financing activities; and the investment contract safe harbor rule. The safe harbor mechanism originates from the concept proposed by SEC Commissioner Hester Peirce in 2020. It will provide crypto projects with a three-year decentralized grace period, during which project teams can focus on decentralizing the network, and the tokens will not automatically be classified as securities.

For the crypto industry, a clear safe harbor framework could significantly change the decision logic of project founders. Previously, many projects chose to launch in overseas jurisdictions such as Switzerland and Singapore due to regulatory uncertainty. If the framework lands successfully, it is expected to reverse the trend of capital outflows and encourage more risk capital and innovation activities based in the United States.

FDIC Banking Standards: Stablecoin Issuance Compliance Thresholds Under the GENIUS Act

On April 7, 2026, the FDIC voted to approve proposed rules for stablecoin issuing institutions—since the GENIUS Act was signed into law in July 2025, this is the most substantive action by federal banking regulators to implement the law. The rules cover four pillars: reserve asset standards, redemption mechanisms, capital requirements, and risk management.

Issuers must hold safe liquid assets such as cash or U.S. Treasury securities to fully support the stablecoin’s face value; must demonstrate the ability to reliably redeem tokens on a one-to-one basis; must meet minimum capital adequacy standards; and must establish a bank-level risk identification and control framework. The Office of the Comptroller of the Currency previously proposed similar requirements for non-bank issuers, including a minimum capital threshold of $5 million.

What needs particular attention is that the rules explicitly state that stablecoin payments are not covered by federal deposit insurance, and prohibit issuers from paying interest or returns to token holders in any form. This provision is consistent with the compromise plan reached by the Senate on the CLARITY Act’s stablecoin yield provisions. During a 60-day public comment period, the rule will solicit industry feedback on 144 specific questions. The final rule is expected to be completed by July 18, 2026.

Cross-Agency Coordination: How the SEC and CFTC End the Regulatory Turf War

On March 11, 2026, the SEC and CFTC formally signed a new Memorandum of Understanding, clarifying coordination mechanisms for areas where their jurisdictions overlap. The Memorandum of Understanding emphasizes respecting each agency’s statutory authority, regulatory efficiency, and good-faith communication; it explicitly opposes a “turf war” mindset; and it proposes that regulation should be carried out through fair notice rather than enforcement measures.

The Memorandum of Understanding identifies several priority areas for coordination: clarifying product definitions through joint interpretations and rulemaking; advancing modernization of clearing and margin frameworks; reducing regulatory friction for dual-registered entities; and providing practical regulatory frameworks for crypto assets. The two sides also announced that “crypto projects” will shift from being led solely by the SEC to being jointly advanced, with the goal of coordinating federal oversight of the digital asset market.

SEC Chair Atkins said that the SEC is “revisiting its coordination agreement with the aim of ending duplicative enforcement actions.” CFTC Chair Selig stated that regulatory coordination work has “fully commenced,” and that regulators can now cooperate with the industry in ways that were previously impossible when their pace did not align. The establishment of this coordination mechanism lays institutional groundwork for implementing the rules after the passage of the CLARITY Act.

Treasury Rules: Anti-Money Laundering Compliance Will Reshape the Stablecoin Operating Structure

The Financial Crimes Enforcement Network and the Office of Foreign Assets Control under the Treasury Department jointly released proposed rules on April 8, 2026, requiring stablecoin issuers to comply with obligations under the Bank Secrecy Act. This means stablecoin issuers will need to establish anti-money laundering, customer identification, and suspicious activity reporting mechanisms at the same level as traditional financial institutions.

Treasury Secretary Bessen—previously stated that “economic security is national security,” viewing regulation of the crypto market as a national priority. The Treasury Secretary also chairs the “Stablecoin Certification Review Committee,” which is responsible for assessing whether state-level regulatory regimes meet federal standards—this mechanism directly affects whether small issuers with total outstanding amounts not exceeding $10 billion can choose to accept state-level regulation.

The implementation of anti-money laundering rules will have structural effects on the operating costs of stablecoin issuers. Building compliance systems, deploying monitoring systems, and fulfilling reporting obligations will all become operational variables that issuers must take into account. How the Treasury rules interface with FDIC prudential standards and the SEC securities classification framework will be a core issue the industry will focus on next.

Prediction Market Signals: The Game Logic Behind the 63% Passing Probability

Polymarket data shows that the probability of the CLARITY Act being signed into law in 2026 has recently fluctuated. It rose to 71% to 72% in the late March period, then fell back to around 54% due to industry disagreements over the stablecoin yield compromise plan, stabilizing at around 63% as of early April. This change trajectory reveals the market’s fine-grained pricing of the legislative process.

The key game focus behind the probability fluctuations includes: crypto companies such as Coinbase holding reservations about the specific terms of the compromise plan; a split within the industry on stablecoin incentive issues; some companies believing that giving up certain yield mechanisms is too costly; and others believing that the risk of losing the overall legislative framework is greater. White House crypto adviser Patrick Witt said on social media that “everything will be resolved,” implying that coordination at the administrative level is still ongoing.

Prediction markets provide a real-time market expectation and pricing tool for the regulatory process. However, it is important to note that the probability in prediction markets is essentially the collective judgment of market participants, not a deterministic forecast. Variables that affect the final outcome include the Senate Banking Committee’s review schedule, the progress of bipartisan negotiations on remaining disagreements, and the White House’s attitude toward the final text.

Formation of the Dual-Track System and Scenario Analysis of Industry Impact

The U.S. cryptocurrency regulatory landscape is taking shape as a clear dual-track system: a market-structure framework for crypto-native companies advancing in parallel with a prudential framework for stablecoins issued by banks and their subsidiaries. The former is centered on the CLARITY Act and the SEC’s “Reg Crypto,” addressing foundational issues such as token classification, exchange registration, and market conduct. The latter is carried through the GENIUS Act along with FDIC and OCC implementation details, establishing federal prudential standards for stablecoin issuance.

From the perspective of industry impact, implementing the regulatory frameworks will bring several structural changes. Compliance costs will rise—issuers will need to build reserve management, capital adequacy, and risk-control systems that meet bank standards. The competitive landscape will be reshaped—institutions holding bank licenses may gain a first-mover advantage in stablecoin issuance. Capital flow routes may adjust—clear regulatory frameworks could attract institutional capital that had previously been watching from the sidelines.

At the same time, regulatory implementation also means a significant increase in compliance burdens. For mid-sized and smaller issuers that cannot meet capital thresholds or bank-level compliance requirements, exiting or transforming may become a realistic option. The balance between regulatory certainty and market vitality will be the key variable to watch next.

Summary

In April 2026, the U.S. cryptocurrency regulatory landscape entered a dense period of overlapping advances in legislation, institutional rules, and cross-department coordination. The CLARITY Act reached a compromise on stablecoin yield issues, with the Senate’s review moving into a critical stage. The SEC’s “Reg Crypto” framework was submitted to the White House for review, and three exemption mechanisms provide the industry with clear compliance pathways. FDIC proposed rules based on the GENIUS Act introduced tighter bank standards for reserves, capital, and redemption. The SEC-CFTC Memorandum of Understanding ended the long-standing regulatory turf war. The anti-money laundering rules jointly advanced by the Treasury further raised compliance thresholds. With four regulatory axes moving forward in parallel, the dual-track U.S. cryptocurrency regulatory system is moving from blueprint to reality. For market participants, understanding the logic of this framework, identifying compliance red lines, and assessing changes in operating costs will be the core propositions of strategic decision-making in 2026.

FAQ

Q: What stage is the CLARITY Act currently in? When is the vote expected?

The CLARITY Act has already passed the House and is currently in the Senate Banking Committee review stage. The stablecoin yield compromise has been reached, and the Senate Banking Committee is expected to advance the review and voting by the end of April 2026.

Q: What core exemptions does the SEC’s Reg Crypto framework include?

The framework includes three exemption mechanisms: the startup exemption (a four-year grace period), the fundraising exemption (structured disclosure obligations), and the investment contract safe harbor rule (a three-year decentralized grace period).

Q: What specific requirements does the FDIC’s new stablecoin rule impose on issuers?

The FDIC proposed rules require issuers to hold safe assets such as cash or U.S. Treasuries to fully back the stablecoin’s face value, ensure reliable one-to-one redemption capability, meet minimum capital adequacy standards, and establish bank-level risk management frameworks. Payment stablecoins do not enjoy coverage under federal deposit insurance, and issuers are prohibited from paying interest or returns to stablecoin holders.

Q: What problem did the SEC and CFTC coordination Memorandum of Understanding resolve?

The two sides signed a Memorandum of Understanding in March 2026 to clarify coordination mechanisms in overlapping jurisdiction areas, establish that they will clarify product definitions through joint interpretation, reduce redundant regulation, and move away from the cooperative principle of “regulating through enforcement.”

Q: How should the 63% passing probability of the CLARITY Act on Polymarket be interpreted?

This probability reflects the market’s collective judgment of the legislative process. It has fluctuated previously due to industry disagreements on the compromise plan. The probability itself is not a deterministic forecast; the actual outcome depends on the Senate review schedule, the progress of negotiations between the two parties, and the level of White House coordination.

Q: What does the dual-track U.S. cryptocurrency regulatory system specifically refer to?

The dual-track system includes: (1) a market structure framework for crypto-native companies (centered on the CLARITY Act and the SEC’s “Reg Crypto”) and (2) a prudential framework for stablecoins issued by banks and their subsidiaries (carried by the GENIUS Act and FDIC and OCC implementation details). The two tracks move in parallel, covering the major participants and business types in the digital asset market.

Q: What impact will the implementation of the regulatory framework have on stablecoin issuers?

Issuers will face higher compliance costs and need to establish bank-level reserve management, capital adequacy, and risk control systems. Institutions with bank licenses may have an edge in competition, while mid-sized and smaller issuers that cannot meet compliance thresholds may face exit or transformation pressure.