This timeline tracks the procedural sequence the repository can directly support for GENIUS implementation. It separates Treasury's implementation ANPRM and state-similarity proposal from the separate Treasury illicit-finance RFC stream, and it distinguishes official agency actions from trade-association letters, coalition letters, portal pages, and the March 2026 Treasury report.
This page covers only the post-enactment GENIUS implementation slice currently summarized in GENIUS Act implementation, 2025-2026. It includes official Treasury, OCC, FDIC, and NCUA rulemaking milestones, a limited set of submitted comment artifacts already present in the repo, and one final Treasury report-level artifact. It does not attempt to reconstruct full docket coverage, every stakeholder submission, or the broader stablecoin-policy debate outside this implementation sequence.
- Actor / agency: Treasury
- Event label: Treasury extends ANPRM comment period
- Evidence class: official agency action
- Description: A Federal Register notice extends Treasury's GENIUS implementation ANPRM comment deadline to November 4, 2025. This gives the repo a cleaner procedural bridge between the September launch notice and the early-November bank-trade comment activity already captured locally for provenance.
- Source basis: GENIUS Act implementation, 2025-2026, GENIUS Act Implementation, 47251 (2025-19093)
- Actor / agency: Bank Policy Institute and The Clearing House
- Event label: Treasury illicit-finance RFC response submitted
- Evidence class: coalition comment letter
- Description: A BPI / TCH PDF preserves one submitted response to Treasury's separate request for comment on illicit activity involving digital assets. This is the earliest direct comment artifact in the repo for the illicit-finance stream, not the Treasury implementation ANPRM stream.
- Source basis: GENIUS Act implementation, 2025-2026, BPI / TCH response to Treasury RFC on digital-asset illicit finance
- 2025-09-19 and 2025-10-01 establish the Treasury implementation ANPRM stream as a formal rulemaking process with a documented extension path rather than only post-enactment messaging.
- 2025-10-17 and 2025-11 show that the repo now has a real but still selective comment record for two different Treasury-related streams.
- 2025-12-16 to 2026-03-02 is the main agency-rulemaking buildout, with FDIC, NCUA, and OCC each entering the record through official notice or bulletin material.
- 2026-03 and 2026-04 show Treasury splitting between a report-level illicit-finance output and a separate state-similarity proposal path.
- The repository still lacks direct docket or Regulations.gov captures for most of these proceedings, so this page should not be read as a complete public-comment chronology.
- The repo has direct illicit-finance comment artifacts and the March 2026 Treasury report, but it does not yet preserve the underlying Treasury or FinCEN RFC notice as a separate raw capture. That is why the illicit-finance thread begins here with comment artifacts rather than a direct official launch notice.
- NCUA has portal coverage and a due date, but the repo still lacks direct submitted NCUA comment-letter artifacts.
- FinCEN still lacks direct submitted comment files in the repo even though it appears in Treasury implementation notice coverage.
¶ Source access and local retention
Atlas Trace retains a local research capture for provenance of the sources
described in this page. The capture and processing records remain local; they
are not available through this wiki. Consult the identified sources for public
access options where available. See Sources, access, and local retention.