Earlier this year, President Donald Trump promised a “21st Century” payments upgrade without requiring a central bank digital currency, putting the GENIUS Act at the center of the plan.
The law is already on the books; the operating rulebook is not yet.
In July, Trump praised the crypto industry, declaring:
“You have certainly as an industry gone up more than anybody. Nobody’s gained the respect in such a short period of time.”
He went on to make an enormous promise to the industry he now greatly admires,
“Many Americans are unaware that behind the scenes, the technical backbone of the financial system is decades out of date[…] but payments and money transfers are costly and take days or even weeks to clear.
Under this bill, the entire ancient system will be eligible for a 21st-century upgrade using the state-of-the-art crypto technology[…]
This will increase demand for US treasuries, lower interest rates and secure the dollar’s status as the world’s reserve currency for generations to come.”
Trump also stated that he believes stablecoins help protect the dollar. He asserted that he is “not going to let the dollar slide,” because with a “smart president, you’re never going to let the dollar slide.”
When he gave that speech, the dollar had fallen 12% since he took office in January. After, it increased by 3% over the subsequent months.
Notably, when the dollar slid, Bitcoin soared. Now the dollar is recovering, and Bitcoin is in decline.
Can Trump have his dollar cake without eating crypto, too?
The Treasury initiated GENIUS Act processes on September 18 with an advance notice of proposed rulemaking that seeks input on how to license issuers, establish capital and liquidity requirements, and define bank-permissible activities.
The consultation window is the first step toward binding standards that would allow banks and payments firms to issue fully backed dollar stablecoins under federal oversight.
From banning CBDCs to rewiring the payments stack
The original promise was framed as upgrading an “ancient” stack without building a CBDC.
In an executive action signed Jan. 23, Trump created a CBDC ban, and bills to codify it have cleared the House but are not yet law. The policy direction is set, while statutory endpoints and detailed implementation are pending.
Supervision has shifted in a way that matters for banks seeking to integrate with crypto rails. This spring, the OCC, Federal Reserve, and FDIC withdrew earlier “ask permission first” guardrails and reopened custody, stablecoin, and payment DLT activities, which will reduce friction once the Treasury finalizes the standards.
The OCC also issued specific bulletins on bank activities related to digital assets, reestablishing permissible paths under review for safety and soundness. According to the OCC, clarity on permissible activities will sit alongside the GENIUS regime for issuers and payment stablecoin service intermediaries.
Throughput on public stablecoin rails is already substantial by on-chain measures, although a significant share is intra-exchange and automated, rather than point-of-sale spending. Industry research from McKinsey frames the stablecoin thesis as tokenized cash for settlement and treasury, not a consumer swipe replacement on day one.
According to McKinsey, distribution and last-mile integration drive real-economy impact once backing standards converge under rules like GENIUS. After reserves are standardized, competition shifts to who controls distribution between merchants, acquirers, and wallets.
Instant rails catch up to crypto speed
Legacy instant rails are not standing still. According to the Federal Reserve’s FedNow statistics, the network settled 2.5 million payments totaling $307 billion in the third quarter.
The private Real-Time Payments network processed $481 billion in the second quarter, with a single-day record of 1.81 million transactions and $5.2 billion on October 3. Swift states that 90% of cross-border payments now reach the destination bank within one hour on GPI, which narrows the speed gap that once separated public chains from correspondent banking.
The competitive wedge for crypto rails centers on 24/7 uptime, weekend and cross-border settlement, programmability, and capital efficiency at the treasury layer, rather than raw domestic speed.
The pipes that connect those advantages to everyday commerce are turning on. Visa has expanded stablecoin settlement support across more currencies and chains, and is extending this capability with additional acquirers.
Mastercard unveiled end-to-end capabilities to power stablecoin transactions from wallets to checkouts, and began regional settlement rollouts for USDC and EURC in corridors where cross-border friction is highest.
According to Visa Investor Relations and Mastercard, these integrations enable the movement of stablecoins into acquirer-ledgers and settlement files without altering the consumer checkout experience.
Pilots with fintech infrastructure providers, including those with Finastra and regional partners, demonstrate that operating rails are live in limited forms. Acquirer and PSP adoption can scale with more explicit rules on liability, capital, and reserve composition.
When the ‘replacement’ becomes measurable
Policy timing sets the boundary for when a “replacement” rail can be measured in production. Based on the administrative sequence, Treasury’s ANPRM in September is typically followed by a notice of proposed rulemaking in the subsequent quarters, then a final rule after a comment cycle.
According to the Treasury docket, the final GENIUS rules are scheduled for implementation in 2026, pending adherence to timelines. In parallel, banking agencies must set capital, liquidity, and supervision standards for PPSIs and for banks that hold reserves or intermediate stablecoin settlement.
Market-structure legislation, including the Digital Asset Market Clarity Act that passed the House in July, would clarify the treatment of exchanges and commodities versus securities, but has less direct impact on payments on day one.
Forward adoption will depend on whether card networks and acquirers shift their settlement to stablecoins, which can reduce costs or shorten the time. The realistic near-term path is replacement in settlement, not at the point of sale.
PSPs and acquirers can net merchant receivables in USDC or EURC on weekends or across borders, then utilize bank funds where they are cheaper or where policy requires it.
If that approach scales, the front end remains the same for consumers while the back end routes across multiple rails. According to Mastercard, multi-rail acceptance is already a program goal.
For banks, the revived OCC guidance means that reserve custody, tokenized cash activities, and payments DLT can be situated under existing risk frameworks once final rules define eligibility and oversight.
Stablecoins, Treasuries, and the dollar strategy behind GENIUS
The dollar strategy embedded in GENIUS relies on fully backed reserves held in Treasury bills and cash. If supply and distribution expand under federal licensing, the reserve base forms a recurring bid for short-dated U.S. government debt.
A larger stablecoin float channels demand into 1- to 3-month bills, thereby reinforcing dollar distribution abroad, provided that par convertibility and intraday liquidity are robust.
J.P. Morgan has published a conservative forecast around the scale of the market, while McKinsey and Standard Chartered outline larger end states. The range matters less than convertibility, audits, and narrow-banking-style safeguards that address bank supervisors’ concerns about the singleness of money, elasticity, and integrity.
There is a competing path where public stablecoins cap out and bank-led tokenized deposits take the lead. The Bank for International Settlements outlines a next-generation system built around tokenized deposits and unified ledgers anchored in central bank reserves.
Along this path, most real-economy flows utilize FedNow, RTP, and SWIFT GPI both domestically and cross-border, with tokenization integrated within bank balance sheets and wholesale platforms. Public stablecoins then remain a crypto-native rail with ring-fenced use.
The outcome hinges on how U.S. rules resolve bank access, capital, and liquidity, as well as how card and acquirer networks price weekend and foreign exchange corridors.
The early scorecard on Trump’s ‘replacement’ system
Near-term scorecards point to motion, not completion. Rules are in consultation, OCC and the Fed have softened posture on bank participation, SEC leadership has turned over, and the card networks are deploying.
Missing pieces are the final GENIUS regulations, coordinated bank capital and liquidity treatments for PPSIs and bank intermediaries, and scaled acquirer adoption inside the largest merchant processors.
Meanwhile, instant rails are compounding. According to FRB Services, FedNow value and volume are expanding quarter over quarter. RTP’s throughput and transaction limits have risen, which reduces the domestic gap crypto once exploited.
For readers tracking whether the replacement is genuine, watch metrics that test the settlement thesis rather than relying on consumer-facing anecdotes. The key dates to log are Treasury’s NPRM and final rule milestones, OCC and Fed capital and liquidity specifics, and acquirer dashboards that display the share of merchant settlements routed to stablecoins by corridor and day of the week.
Monitor the number of banks that hold stablecoin reserves and operate on- and off-ramps under OCC guidance. Compare stablecoin weekend and FX costs against Swift GPI routes at the corridor level. Track aggregate Treasury bill holdings by licensed issuers against auction sizes. These are the gauges that convert political promises into measurable payments infrastructure.
| Rail | Recent datapoint | Source |
|---|---|---|
| FedNow | $307B settled in Q3 2025, 2.5M payments | FRB Services |
| RTP | $481B in Q2 2025, Oct. 3 record 1.81M tx / $5.2B | PYMNTS |
| Swift GPI | 90% reach destination bank within one hour | Swift |
| Visa | Expanded stablecoin settlement support, more coins and chains | Visa IR |
| Mastercard | End-to-end stablecoin capabilities live in select regions | Mastercard |
| GENIUS rules | ANPRM opened Sept. 18, 2025 | U.S. Treasury |
In short, crypto is emerging as a settlement layer within multi-rail payments, while the consumer experience remains the same.
The real turning point occurs once GENIUS rules are finalized and acquirer adoption is reflected in measurable settlement flows.
Is Trump on track to deliver a true ‘replacement’?
So far, Trump has set a direction rather than built a finished system. The CBDC ban, the GENIUS framework, and a friendlier stance from the OCC and Fed toward bank participation all move U.S. policy toward crypto-based settlement rails.
Card networks and PSPs are wiring those rails into production, and banks are being told what “permissible” looks like. That is real progress toward a crypto-native settlement layer.
But a full replacement of legacy rails is nowhere near done. FedNow, RTP, and Swift GPI are scaling in parallel, not being switched off. GENIUS standards are still under consultation, bank capital rules for PPSIs remain unresolved, and acquirer adoption is in early pilots rather than being system-wide mandates.
Even on an aggressive timeline, most of the heavy lifting, including final rules, bank balance-sheet treatment, and cross-border corridor build-out, will occur in 2026, and realization is likely to extend beyond his second term.
The most realistic outcome is not a clean swap of one system for another, but a multi-rail stack where stablecoins and tokenized deposits handle settlement in the background while cards and instant bank transfers remain the consumer touch points.
In that world, Trump can credibly argue that he pushed the system toward crypto rails and away from a CBDC, but the “replacement” he promised will look more like a gradually rewired back end than a flag day where legacy rails disappear.
So is he on track?
At this stage, he is on track to influence how the next-generation stack is wired, rather than entirely replacing legacy rails in a single term.
The scorecard today reads: policy momentum and live pilots, but no decisive break where the bulk of U.S. and global retail payments move onto crypto settlement.
Until bank capital and liquidity standards are finalized, and acquirer dashboards show stablecoins carrying a meaningful share of settlement, Trump’s replacement remains a thesis in progress, not a fully developed system.
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