The mechanism. The GENIUS Act, signed into law in July 2025, doesn't just legalize stablecoins — it dictates exactly where the money backing them has to sit. Issuers must hold reserves 1:1 in cash, insured-bank demand deposits, Treasury bills of 93 days or less, and short-dated repo collateralized by those bills. Reserves can't be rehypothecated except narrowly for redemption liquidity, and custody must sit with a bank, credit union, SEC-registered entity, or CFTC-regulated custodian that segregates the assets from its own balance sheet. That's a federal mandate to route a fast-growing pool of dollars — Circle alone runs tens of billions in reserves — through a small set of qualified custodians and government money-market funds. Every dollar of stablecoin issuance now has to pass through someone's custody ledger and someone's Treasury money-market fund before it can back a token. That's fee income on float that scales with stablecoin supply, not with issuer profit margins.
The GENIUS Act's Real Winners Are the Custodians Holding Stablecoin Reserves, Not the Issuers
Federal law now forces every stablecoin issuer to park reserves in short-term Treasuries and cash at regulated banks and money-market managers — turning custodians and fund managers into the toll collectors on crypto's fastest-growing float.
| Ticker | Company | 1-year change |
|---|---|---|
| COIN | Coinbase | −55.4% |
| HOOD | Robinhood | −21.8% |
| MSTR | Strategy (MicroStrategy) | −69.4% |
Every dollar of stablecoin issuance now has to pass through someone's custody ledger and someone's Treasury money-market fund before it can back a token.
Who cashes in. The clearest beneficiary is the custody-and-asset-management layer sitting underneath the issuers, not the issuers themselves. Coinbase COIN co-founded Circle's USDC arrangement and earns a contractual share of reserve interest income from Circle's reserve portfolio — a claim on the Treasury yield generated by USDC float that doesn't depend on Coinbase's trading volumes at all, and grows automatically as USDC's regulatory tailwind expands issuance. Robinhood HOOD is pushing further into stablecoin infrastructure and tokenized products, positioning to capture the same custody/cash-management fee stack as compliant stablecoin rails scale under a codified federal regime. Traditional custody banks that already service Circle-style reserve structures — the BNY Mellon/BlackRock model, where a 2a-7 government money-market fund holds the Treasuries and a global custodian holds the fund — are the purest expression of this thesis: they earn custody and fund-management fees on reserve balances regardless of which stablecoin brand wins market share.
Who is exposed. MicroStrategy/Strategy MSTR carries no exposure to the reserve-custody float — its balance sheet is a leveraged bitcoin bet, unrelated to stablecoin plumbing, and gets no lift from this rule. Marathon (MARA) and Riot RIOT are pure-play bitcoin miners; GENIUS Act custody rules govern stablecoin reserves, not mining economics, so these tickers are simply the wrong wrapper for this trade despite sitting in the same "crypto" sector bucket. Block XYZ's Cash App stablecoin ambitions are real but nascent — it's a potential future entrant into the custody-fee stack, not yet a demonstrated beneficiary.
The play. Watch which banks and asset managers disclose growing stablecoin-reserve custody mandates in 10-Qs — that fee line scales with total stablecoin supply outstanding, a cleaner macro bet than picking the winning issuer.
Source: original report ↗
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