Two US regulatory threads just lined up. The GENIUS Act created a federal pathway to issue payment stablecoins, and the OCC's new rule lets national trust banks hold digital assets in non-fiduciary custody - then conditionally chartered Coinbase as one. Issuance and custody can now sit inside the same federally regulated counterparty.
SoFi Bank put SoFiUSD on Mastercard's settlement layer. Authorization still rides the card rails and the merchant sees nothing change, but the interbank fund movement happens on-chain, around the clock, with no batch window and no correspondent float. For the first time, issuers and acquirers get to choose their settlement medium.
An invoice agent hits a transient timeout, retries, and two payments clear to the same vendor. The model calls it success. Ops calls it a week of cleanup. Spend limits and roles are a speed bump. Real delegated authority is a delegation object, policy on every attempt, ledger-bound idempotency, and an instant kill switch.
A payroll rollout taught me the friction is never the integration. It is funding caps, routing permissions, and what can clear directly versus what has to detour through a sponsor bank. That is why the Fed's new payment-account RFI matters - access is becoming a design decision, not just a policy one.
From March 2026, Nacha standardizes the ACH Company Entry Description as PAYROLL or PURCHASE for those payment types. It sounds trivial, but a free-text field becoming a dependable category is what finally lets reconciliation automation stick on a rail that still moves tens of billions of payments a year.
FedNow matched RTP at a $10M network limit in November 2025 and added new risk rails - a receiver-account pre-check pilot, ScamClassifier reporting, an Exception Resolution Service, and 1,500+ banks live. Instant is treasury cash now, and batch-era controls just got a 24/7 bypass.