"The Treasury Department has broken the regulatory silence surrounding the GENIUS Act. The core of the rule is the $10 billion threshold. Issuers with consolidated total outstanding issuance of $10 billion or less may opt for state regulation, provided their home state's regime passes the SCRC's "substantially similar" test. Issuers exceeding that $10 billion cap are excluded from the state pathway and must transition to the federal framework within 360 days, unless they secure a specific waiver.  Tether and Circle are well above the $10 billion mark and are barred from the state-level route."