Points of Focus

• US banking groups say tokenized deposits are already FDIC-insured.
• They want technology-neutral rules so banks can offer blockchain deposits without extra approvals.
• The FDIC comment period closed ahead of the July 18 GENIUS Act deadline.

The Bank Policy Institute (BPI), The Clearing House Association (TCH), and the Consumer Bankers Association (CBA) submitted a joint comment letter to the Federal Deposit Insurance Corporation (FDIC) on June 9, responding to the agency’s notice of proposed rulemaking on GENIUS Act standards for FDIC-supervised Permitted Payment Stablecoin Issuers. 

The three organizations, which collectively represent virtually every major US bank, focused their comment entirely on a single question: whether tokenized deposits, bank deposits recorded on blockchain or distributed ledger infrastructure, qualify for FDIC deposit insurance under existing law.

Their answer is yes. They ask that the FDIC say so explicitly.

The argument

The Federal Deposit Insurance Act defines a deposit by its economic substance, not by how it is recorded. A bank’s obligation to return a customer’s funds does not change because that obligation is represented by a blockchain token rather than a database entry. BPI, TCH, and CBA argue that the FDIA is clear on this point and that the FDIC’s proposed regulations correctly apply a technology-neutral approach.

“The insured status of those funds is a critical consideration for institutions in considering whether to pursue the development of such products,” the letter states. 

The organizations specifically welcome two aspects of the FDIC’s proposal: 

• The definition of a deposit does not depend on the technology used to represent or record the obligation. 
• The FDIC’s recordkeeping requirements are equally technology-neutral, allowing banks to use blockchain infrastructure for recording deposit liabilities for insurance determination purposes without seeking a separate waiver.

The distinction matters because tokenized bank deposits currently sit in a regulatory gray area. If treated as deposits, they qualify for FDIC insurance and banking protections; if classified as payment stablecoins, they fall under separate reserve and redemption rules without access to the traditional banking safety net. 

Codifying technology neutrality collapses that ambiguity for every FDIC-supervised bank simultaneously.

The stablecoin distinction

The comment arrives as the stablecoin market has its most year of product launches in history. 

• SoFiUSD, launched May 27, is explicitly structured as a platform balance rather than a bank account because it is not FDIC-insured. 
• MoneyGram’s MGUSD, launched June 2, similarly carries no deposit insurance. 
• Deel’s DLUSD, launched June 3, explicitly states that the FDIC or any equivalent does not insure it.

If the FDIC adopts a technology-neutral framework, banks could issue blockchain-based deposits as insured products, replacing the uninsured structures that currently dominate stablecoin offerings. 

Source: https://t.co/grxW2yzEoi

— Wu Blockchain (@WuBlockchain) April 7, 2026

The regulatory timeline

The FDIC’s BSA and sanctions compliance rule, approved May 22 as the third GENIUS Act rulemaking, opened a 60-day public comment period. The BPI, TCH, and CBA letter is the first major banking-industry response to be entered into the public record. 

With the GENIUS Act’s one-year implementing rules deadline falling on July 18, the FDIC faces pressure to finalize its technology-neutral approach before then. The FDIC’s proposed rulemaking explicitly covers BSA and sanctions compliance, with the technology-neutral deposit insurance clarification as a parallel but related track.

The banking industry argues blockchain is simply a record-keeping technology, not a new regulatory category. The FDIC’s decision could determine whether that view becomes law before the GENIUS Act’s first rules take effect later this year.