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Markets · November 7, 2026 · 2 min read

BPI reserve analysis separates onshore stablecoins from offshore and crypto-backed tokens

By Econ Data Tools Editorial Team

Published November 7, 2026 • Updated November 7, 2026

BPI finds two of the ten largest dollar stablecoins aligned with GENIUS reserve standards in its June snapshot. The 72% outside those standards is not a finding that all of those tokens face the same U.S. compliance deadline.

The Bank Policy Institute published a reserve-asset analysis on November 6 and highlighted it in its November 7 roundup. It finds that two of the ten largest dollar stablecoins, representing 26% of outstanding tokens in the analysis, held assets aligned with GENIUS Act reserve standards. The underlying snapshot is generally June 30, 2026, not a November compliance audit. The distinction between reserve composition and legal scope matters. BPI groups the tokens into onshore issuers expected to face the requirements, offshore-offered tokens and crypto-backed tokens outside the framework it analyzes. Its finding that 72% of outstanding tokens fall short of the reserve standards does not mean that all of those tokens face the same U.S. deadline or have been found in violation. Four of the ten coins are offered onshore and expected to be subject to the requirements, according to BPI. Its June assessment puts Circle USDC and Paxos PYUSD in the aligned group, while World Liberty USD1 and Ripple USD were backed by money-market funds holding agency debt and longer-dated Treasury securities. The latter two accounted for roughly 2% of the outstanding amount in the analysis. BPI assigns 65% of the outstanding amount to offshore-offered stablecoins and 7% to crypto-backed coins. Those categories differ from the onshore group in both reserve structure and regulatory perimeter. The paper is an industry-association analysis, not an enforcement order, an issuer license or a certification by a federal regulator. The OCC says its final GENIUS implementation rule and the Act take effect on January 18, 2027. Its October 21 bulletin describes requirements for permitted issuers and foreign issuers within its jurisdiction, including reserves, redemption, custody and supervision. It says Bank Secrecy Act, anti-money-laundering and sanctions rules are being addressed separately; the bulletin is not a claim that every agency has finalized every rule. Reserve assets that meet a legal standard do not eliminate de-pegging risk. BPI notes that compliant and non-compliant structures have both traded below their target value in the past. The analysis does not quantify a new wave of Treasury purchases or establish a future yield effect, so its reserve shares should not be turned into a fixed-income forecast.

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