The U.S. Federal Deposit Insurance Corporation, or FDIC, has put forward another reporting form for stablecoin issuers after releasing the weekly PS-01 filing last week. The new proposal, PS-02, is titled “Report of Assets and Income for Permitted Payment Stablecoin Issuers” and would require quarterly submissions covering a full income statement, balance sheet, off-balance-sheet items, and capital position.
That would place bank-style financial disclosure requirements on stablecoin issuers. Unlike PS-01, which is confidential, PS-02 would generally be public. The filing is part of the FDIC’s implementation of the GENIUS Act, the U.S. stablecoin law codified at 12 CFR 350, and remains at the proposal stage.
Quarterly disclosures would be filed on a public basis
PS-02 uses the same “Reports of Condition and Income” wording long associated with banks’ Call Reports. Under the proposal, every issuer registered with the FDIC would have to file the report through FDICconnect within 30 days after the end of each quarter. The filing would include five schedules.
The public disclosure standard is the key difference. Once a filing is accepted by the FDIC, it would be posted on the agency’s website for public review. Issuers could request confidential treatment for specific items, but the threshold is high. A general claim that disclosure would hurt competitiveness would not be enough on its own.
The accountability standard also tracks the bank model. The form would require a named certification from the chief financial officer and sign-off from the full board and senior management.
Balance sheet treatment would classify outstanding stablecoins as liabilities
In the balance sheet schedules, issuers would need to separate reserve assets from non-reserve assets. Reserve assets would include U.S. cash, balances held at the Federal Reserve, deposits, short-term Treasuries maturing within 93 days, overnight reverse repurchase agreements, and qualifying money market funds.
On the liability side, one central line item is the “issuance value of stablecoins outstanding.” In practice, that means stablecoins in circulation that the issuer is obligated to redeem would be reported as liabilities.
The form also asks for crypto-specific disclosures. Issuers would have to report digital assets held to pay validators or miners for “network” or gas fees, as well as assets held separately to satisfy operational buffer requirements.
Capital reporting would adopt bank concepts including CET1
The capital schedule is where the prudential approach is most visible. PS-02 directly imports the bank capital tier structure by requiring issuers to report Common Equity Tier 1, or CET1, and additional tier 1 capital, with eligibility determined under 12 CFR 350.8.
The proposal also requires an “operational buffer.” Issuers would need to hold a separate pool of high-quality assets, sized in relation to total expenses over the prior 12 months, to support continued operations. Eligible assets include cash, Federal Reserve deposits, deposits, and Treasuries. This buffer would have to be calculated separately from reserves.
That setup would require stablecoin issuers to maintain two layers of protection at the same time: redemption reserves and a separate operating continuity buffer.
Memo schedule asks about branded coins, diversification rules, and non-dollar exposure
The final memo schedule gathers several structural disclosures and yes-or-no compliance items the regulator wants to track closely. Issuers would need to report the number of different branded stablecoins they issue and redeem, including white-label stablecoins issued on behalf of third parties.
They would also need to answer, for each business day, whether they complied with the asset diversification and concentration requirements in 12 CFR 350.4(f). The form further asks whether the balance sheet includes any assets or liabilities denominated in currencies other than the U.S. dollar.
Paired with the off-balance-sheet schedule for derivatives, the FDIC would also receive notional amounts and fair values across digital asset, interest rate, foreign exchange, and equity contracts. The proposed structure would give regulators a consolidated view of issuers’ financial condition, capital depth, and potential risk exposures.