A hypothetical payment stablecoin issuer with $1 billion in circulation and no revenue from non-reserve activities would face a $20 million baseline operational-risk capital charge under the Federal Reserve’s proposal announced Sept. 24. A separate loss-history adjustment and any other applicable capital charges would still apply. The issuer would also have to maintain eligible reserve assets with a fair value at least equal to the par value of its outstanding coins. Under the Fed’s formula, the issuance component is charged at 2% on the first $20 billion of payment stablecoins, 1.5% on the next $30 billion and 1% above $50 billion. The Board would also add 25% of the issuer’s three-year average annual revenue from non-reserve assets. At $10 billion outstanding and no non-reserve revenue, the baseline issuance component would be $200 million. A proposed loss scalar could increase or decrease the operational-risk charge based on realized losses, while total capital could include other components. The Fed would separately apply a 2% capital charge to reserve assets consisting of uninsured deposit claims or undercollateralized reverse repurchase agreements. The framework would cover approved stablecoin-issuing subsidiaries of insured state member banks and certain qualifying state-chartered issuers transitioning to Fed supervision under the GENIUS Act. The second category is limited to uninsured state-chartered depository institutions with at least $10 billion in payment stablecoins outstanding. The OCC’s March proposal takes a different approach, setting initial capital for a newly chartered or licensed issuer according to its business plan and risks, generally subject to a $5 million de novo floor, and requiring liquid assets equal to 12 months of total expenses outside stablecoin reserves. Both frameworks remain subject to rulemaking, and final capital and liquidity requirements have not been determined.