US-MD: Stablecoins & Digital Money

Stablecoins & Digital Money

The Maryland Stablecoin Act (SB662/HB1355) was signed and takes effect January 1, 2027, establishing the Office of Financial Regulation as Maryland's stablecoin regulator. Nondepository trust companies must disclose stablecoin intent in their articles of incorporation and obtain Commissioner authorization before engaging in stablecoin activity, while banks and credit unions must notify the Office of Financial Regulation before seeking federal Permitted Payment Stablecoin Issuer approval, an explicit structural link between the state regime and the federal track rather than two wholly independent supervisory tracks. The safeguarding standard behind the Act is modeled directly on the federal GENIUS Act framework, indicating Maryland's intent to align with, rather than diverge from, the emerging federal baseline even while building its own supervisory capacity ahead of federal finality.

This state-level build-out runs concurrently with the kiosk-oversight expansion under SB741, which brings software-based virtual-currency-kiosk operators into registration, giving Maryland a more complete supervisory picture across both stablecoin issuance and a common retail on/off-ramp channel for digital assets within the same legislative cycle. Both bank and nonbank actors are implicated: nondepository trust companies face a new authorization gate, while depository institutions face a new notification requirement layered on top of their existing federal posture.

The central near-term question is how Maryland's state-level stablecoin authorization interacts operationally with the federal GENIUS Act Permitted Payment Stablecoin Issuer framework once that framework's final compliance rules are adopted; the Act's January 1, 2027 effective date sits close enough to the federal track's expected timeline that the sequencing of the two approvals is itself a market-access variable for prospective issuers.