Stablecoins Get a Framework. Now What?
There’s a particular kind of meeting that follows a new technology getting its first credible framework. Someone read a headline that someone else forwarded. By the time I'm in the room, the questions are already running ahead of the facts. Are we missing something? Is this where things are going? Do we need to move?
Recently, those questions have clustered around the impact of stablecoins on retail banking. They are digital tokens pegged to traditional currencies that can move across blockchain networks without relying on traditional banking rails. The GENIUS Act is what brought them into focus: a U.S. regulatory framework that defines how stablecoins must be backed, governed, and supervised. It doesn't force adoption or change how payments work overnight. It removes ambiguity. And once ambiguity is removed, the conversation changes.
That shift has a familiar momentum. The conversation accelerates, timelines compress, and someone in the room starts to sound very certain, willing to say it will change everything, that those who move first will be rewarded. Occasionally, they are right. More often, they are early. The conversation moves faster than the system itself, and that gap is where bad decisions get made.
The financial systems that matter move more slowly than the conversation around them, and payments move slower than most. Behavior is deeply ingrained: consumers use what works, merchants optimize for cost, networks evolve but rarely disappear. What stablecoins have the potential to change isn't the experience of paying, but the economics underneath it. To see why, we need to look at how payments work. At a high level, there are three layers: the experience layer that customers see through cards, wallets, and banking apps; the network layer where Visa, Mastercard, and processors route transactions and generate interchange fees; and the settlement layer where money moves between institutions. Today, stablecoins operate at the settlement layer and leave the payment experience intact. They have not displaced cards, wallets, and apps in everyday transactions. Whether that holds as the technology matures is the real question, but confusing the current state with the possible future leads to bad strategy.
Two paths emerge. In the first, stablecoins bypass the network layer entirely: payments move directly between wallets and merchants, interchange fees disappear, and costs drop for merchants, but so do consumer protections like fraud handling and chargebacks. In the second, stablecoins are absorbed into existing networks, the customer experience stays the same, and settlement becomes faster and cheaper behind the scenes. Most of the perceived risk on banks comes from the first path, even though the second is more likely.
Stablecoins only disrupt payments materially if three things happen at the same time, which is a much higher bar than most commentary suggests. Merchants need a reason to push, consumers need a reason to switch, and traditional payment networks need to fail to adapt. Today, only one of those conditions is clearly in place. Merchants have a real incentive to reduce fees. Consumers, for the most part, do not. And networks are already moving to integrate stablecoins into their own infrastructure. Most commentary ignores this sequencing problem, assuming that because the technology exists, adoption will follow. In payments, that's rarely how it works. Technology enables change, but incentives determine whether it happens. This is why the disruption narrative feels ahead of reality. The risk is real. It's just not immediate.
The question I'm usually asked is the wrong one: should retail banks move now to adopt stablecoins as a payment system? Framed that way, it pushes toward action before the conditions are clear and encourages investment before there is a reason to invest. A better question is: how prepared do we need to be if this starts to matter? The shift from prediction to positioning removes the need to be right about timing and replaces it with a need to be ready.
The advisory instinct in moments like this is to press toward resolution, to build the case until action feels inevitable. But I've written elsewhere about what good advising looks like in moments like this [link]. The more useful move is to help the room carry the question with more clarity and then define what it would take to act. For most organizations facing the GENIUS Act, that means building modular systems that can connect to new payment rails without replatforming, developing a clear view of which fintech partners you would engage before the pressure arrives, and agreeing in advance on what would actually move you to act — whether that's sustained merchant adoption, measurable consumer demand, or a competitive shift that changes the calculus. None of this requires a large upfront investment, but it does require intent.
By the time the decision is obvious, the question won't be whether to move. It will be whether you built your own path before someone else forced you onto theirs.