I’ve spent most of my career building for banks and credit unions, first at Geezeo and then inside Jack Henry, and the pattern I keep seeing with stablecoins is the same one I saw with PFM and with real-time payments. Institutions treat it as one big decision, and one big decision is easy to postpone. It isn’t one decision. It’s a sequence, and the first steps are smaller than most boards think.
The clock matters this time. The GENIUS Act takes effect in January 2027, and a realistic implementation runs six to nine months. Count backward and the starting gun already fired. An institution that begins today goes live around the middle of next year, and every quarter of deliberation pushes that further out.
I’ll put my one prediction up front. Every bank account will have a wallet address, the same way every account came to have a routing number and then a debit card. The open questions are the order of operations and whether your accountholders get there with you or without you. What follows is the order of operations.
What we’ve learned from bank and credit union pilots so far
We’ve been running pilots and proofs of concept with banks and credit unions for the past year. A few things have held up consistently.
Small first steps get to yes. A bounded, board-approvable project moves. A “stablecoin strategy” stalls.
The core providers are on this, and I know some of that work firsthand. Jack Henry is working with Circle, FIS has Lyriq, and Fiserv has FIUSD. They aren’t going to give up the ledger, and they shouldn’t. The ledger is what they do, and my bet is they end up owning the tokenized deposit layer for most of the industry. Building at core scale just takes time, and some are closer than others. None of the early steps require waiting on that. This runs alongside what you have, and it should meet your core’s rails when they arrive.
Accountholders are not asking for stablecoins, which is exactly why this is easy to dismiss. But watch how the money actually leaves. On the retail side it leaves for speculation. Someone wires $10,000 to Coinbase to buy bitcoin, and Wade Peery has published the data on what happens next. Nearly every community bank in his dataset shows the activity, and where direction can be measured, roughly two dollars went out to crypto platforms for every one that came back, sustained through a full market cycle. The exchange becomes the primary relationship, the idle cash between trades sits in stablecoins, and what left as a brokerage transfer quietly turned into a checking account somewhere else.
The commercial side leaves for a different reason. Treasury payments don’t move because a CFO fell in love with stablecoins. They move because other providers offer faster, cheaper, always-on ways to pay, and stablecoin rails are increasingly the plumbing under those offers. In both cases nobody asked for a stablecoin, and the deposit left anyway.
Common misconceptions about stablecoins in banking
“Our customers aren’t asking for it.” Correct, and the money is leaving anyway. The evidence is in your outbound files, not your suggestion box.
“This is crypto.” It’s dollars on a new rail. GENIUS makes payment stablecoin issuers regulated entities with reserve, redemption, and disclosure requirements. The speculation era and the payments era are different businesses.
“It’s too early.” Stripe paid $1.1B for Bridge. Mastercard just closed on BVNK for up to $1.8B. And this summer more than 140 companies, with Visa, Mastercard, and BlackRock among them, lined up behind the Open USD (OUSD) consortium before the token even went live. The largest names in payments are not making these moves because it’s early. And the implementation math above runs the other direction. A bank that starts this quarter is live after the rules are, not before. Too early is not the risk.
The crawl, walk, run sequence
The short version: in the crawl you accept and move stablecoins, in the walk you build payment capability on them, and in the run you issue and invent.
Crawl
1. Measure the flow. Before anything else, know your exposure. Outbound ACH and wires to exchanges, by dollar and by relationship. This costs you a report, and it turns an abstract debate into a deposit number.
2. Accept deposits, starting with USDC. An accountholder sends USDC, it converts, and dollars land on your balance sheet. If a commercial client wanted to deposit $100,000 in USDC today, most institutions would have to say no. This step fixes that.
3. Simple send and receive. Let accountholders move stablecoins through you instead of around you. Same relationship, same account, new rail.
The crawl phase also carries the policy and disclosure work every banker already knows is coming. Budget the time for it alongside the technology.
Walk
4. A new commercial payment rail. B2B payables, supplier payments, cross-border settlement that clears in seconds on a Sunday. This is where commercial clients feel it.
5. Outsourced liquidity. Mint and redeem through a partner rather than standing up your own desk on day one. You don’t need to own this to get started. But I’ll flag where I think this goes, because it’s one of the few items on this list that graduates. Banks are good at holding assets. It’s the business. In the run phase I expect some institutions to bring liquidity management in-house, and the ones that do will have turned a vendor expense into a balance sheet capability. Start outsourced, and keep the option open.
6. Wallet infrastructure. Bank-branded wallets so the accountholder’s keys and balances sit under your brand and your controls rather than at an exchange.
7. Accept multiple stablecoins. USDC first, then the rest of the permitted issuers as your clients bring them. Stay issuer-neutral. Marrying one issuer in 2026 is like marrying one card network in 1970.
Run
8. Consortium and network participation. Shared settlement networks and bank consortia give institutions your size network economics none of you get alone. To be clear, several of these networks are being built right now and some are further along than the market realizes. Joining early and helping shape them costs little and is worth doing well before this phase. What lands in the run column is moving real volume, and that timing follows the network rollouts, not your readiness.
9. Tokenized deposits. Your own liability, on-chain. This is the endgame for deposit defense, and everything before it is the preparation.
10. New products, asset classes, and vaults. Programmable escrow-based products, tokenized collateral, new fee income that doesn’t exist on today’s rails.
Controls: the part that runs through all of it
Every phase above gets safer or more dangerous based on one thing, whether the controls live inside the transaction or around it. Screening, limits, holds, delay windows, conditional release. On today’s rails those controls are bolted on at the edges. On these rails they can be built into the payment itself, which is the first time in my career the new rail can be safer than the old one. Institutions that insist on that from step one never have to retrofit trust later.
Who to build with: the stablecoin vendor landscape
The vendor landscape has matured fast, and most of it is complementary by design. What helps is knowing the categories, because a real implementation combines several of them.
Issuers like Circle and Paxos stand behind the money itself, the regulated tokens and the reserves backing them. Payment infrastructure providers like BVNK, now part of Mastercard, and Zero Hash handle orchestration, on-ramps and off-ramps, and the money movement. Custody and wallet infrastructure comes from Fireblocks, Utila, and Turnkey, securing the keys and the signing behind every account. Stablecore and DFNS offer a digital asset core, a parallel system of record for tokenized assets that runs alongside the institution’s existing core. Blockchain analytics from Chainalysis, TRM, and Merkle Science extend the monitoring programs banks already run onto the new rails. And we’re building Coinbax to help institutions take the crawl steps and stay with them through the walk and the run, with controls, the screening, limits, holds, and conditional release, traveling with each payment the whole way. We love running.
Match the category to the phase you’re in. The crawl steps need far less of this stack than the run steps do, which is exactly why starting small works.
If you run a bank or credit union and you’re somewhere on this sequence, I’d love to compare notes. And if I’ve missed a step, tell me. That’s how this list got built in the first place.