Can GENIUS Act stablecoin issuers create money in ways not anticipated?

The proposed GENIUS Act introduces potential regulatory loopholes that could grant stablecoin issuers unprecedented balance sheet flexibility, effectively enabling active money creation beyond current expectations. While traditional banking involves money creation through lending, stablecoin issuers are typically viewed as demand-driven entities that do not displace existing bank deposits. Analysis from the White House Council of Economic Advisers suggests that stablecoin issuance is currently a passive process where deposits simply shift between accounts rather than disappearing. However, the GENIUS Act may inadvertently allow issuers to scale operations in ways that deviate from this passive model, potentially mimicking bank-like money creation. This development has largely escaped the scrutiny of the Office of the Comptroller of the Currency and major banking associations during recent rulemaking processes. The implications for the RWA market are significant, as this shift could fundamentally alter the monetary role of stablecoins within the broader financial ecosystem. Understanding this mechanism is critical for regulators aiming to maintain stability as digital assets become increasingly integrated with traditional Treasury-backed instruments.