On The Brink with Castle Island Dana Syracuse and Josh Boehm (Paul Hastings) on the regulatory picture post-Genius (EP.705)
Mar 3, 2026
Josh Boehm, a Paul Hastings partner who advises on bank charters and digital asset regulation, and Dana Syracuse, a Paul Hastings partner focused on stablecoin licensing and OCC strategy, discuss OCC bank-charter momentum and federal versus state pathways. They cover the Genius Act’s rulemaking and federal non-bank options. They also explore tokenization readiness and reserve composition debates.
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Pick A Charter Based On Product And Regulator Fit
- Charter choice depends on both product-market fit and regulatory fit, including regulator durability and staffing.
- Dana Syracuse highlights critical mass of applicants helps regulators build pattern recognition and sustain expertise.
Plan For A Yearlong OCC Approval Timeline
- Expect about 120 days to conditional approval and up to 18 months to meet conditions and open operationally.
- Dana Syracuse warns the end-to-end process is roughly a year of work including policy review and a pre-opening exam.
Genius Creates A New Federal Non-Bank Issuer Path
- Genius creates a federal non-bank stablecoin issuer path supervised by the OCC, but rule details are pending.
- Josh Boehm flags that this new path may be more streamlined than a bank charter depending on forthcoming rules.