Treasury Proposes Distinct Regulatory Burdens for Stablecoin Issuers and DASPs

The Treasury Department has proposed a new rule that distinguishes between stablecoin issuers and other entities involved in their distribution. Under the proposed rule, an issuer is defined as an entity that bears the redemption-at-par obligation and holds out stable value to the public.

Entities that merely move stablecoins around, such as exchanges, custodians, transfer agents, and white-label providers, are considered Digital Asset Service Providers (DASPs). DASPs face different regulatory burdens than issuers, with stricter requirements for licensed entities.

The competitive landscape is currently defined by a stark disparity in regulatory status. As of July 10, 2026, Circle stands as the only issuer with final OCC trust bank approval, operating as the First National Digital Currency Bank. Meanwhile, four other entities, Ripple, BitGo, Fidelity, and Paxos, are still pending pre-opening conditions.

The DASP model is scaling through distribution rather than issuance, leveraging regulated infrastructure to reach over 3,000 community banks and credit unions. The recent Coinbase-Stablecore partnership illustrates this shift, positioning DASPs as the essential plumbing for traditional finance.