Hey, it’s Marc & the 51 team.
I don't think Washington has ever shipped this much crypto policy in a single week. Each one would normally be the headline.
The US Labor Department proposed allowing Bitcoin in 401(k) plans, opening digital assets to $7.7 trillion in American retirement savings.
US Congress advanced a payment stablecoin framework, pushing dollar-backed digital currencies closer to formal regulatory recognition.
The Treasury published its first rule under the GENIUS Act. Under $10B, you stay with your state. Over it, you move to the OCC.
Other highlights we’re watching this week:
U.S. Treasury publishes first GENIUS Act regulation
Arizona opens $7.43B of pension money to crypto
Franklin Templeton settles an acquisition in its own token
Citadel-backed EDX Markets applies for US trust bank charter
Moody’s rates first Bitcoin-backed $100M bond
and much more. Let’s jump in 👇
Top Boardroom Reads
Stablecoins: What Strategic Choices for Europe (Banque de France)
Making the Case for Tokenized Collateral (Nasdaq & The ValueExchange)
Beyond Dollarization: The Rise of Local Currency Stablecoins (Visa & Dune Analytics)
Tokenized Intraday Repo: Balance Sheet Optimization (Finadium & Broadridge)
Global Economic Outlook 2026‑27: The Fog of War (Allianz Research)
Stablecoin Payments at Scale (Artemis)
The Friday newsletter only scratches the surface. A lot more is going on that we’ll tell you in our PRO briefings.
Top Signals This Week
The $500B stablecoin rulebook
The U.S. Department of the Treasury on April 1 published its first regulation under the GENIUS Act, an 87-page proposed rule defining when state stablecoin regimes qualify as equivalent to the federal framework. Issuers under $10 billion can stay under state supervision if their state passes; above that line, they move to the OCC, which published its own 376-page rulemaking in February. The GENIUS Act takes effect by January 2027 at the latest. [RELEASE]
Why this matters: Three regulatory layers are now closing that gap at once: the GENIUS Act banned issuer-to-holder payments, the OCC added a rebuttable presumption targeting affiliate pass-throughs, and last week’s Senate CLARITY Act deal extends the ban to anything “economically equivalent to interest”. Every platform that built its stablecoin business around yield takes a hit: Circle fell 20% on the and Coinbase dropped 11% on the news. The banks got exactly what they lobbied for: the passive yield ban is now written into three concurrent rulemakings. Stablecoin issuance is heading toward $500 billion this year. How the Treasury draws the line between qualifying state regimes and federal oversight in the next 60 days shapes who gets to issue into that market.
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Arizona plugs pensions into the bitcoin reserve
Arizona’s SB1042 cleared the House Rules Committee, authorizing public retirement systems to allocate up to 10% of their portfolios into virtual currency, including through exchange-traded products or, notably, the federal Strategic Bitcoin Reserve for storage. The Arizona State Retirement System manages ~$50B and the Public Safety Personnel Retirement System holds ~$24.3B, putting the combined maximum crypto exposure at $7.43B from a single state. The bill passed the Senate on partisan lines and now sits on the House consent calendar. [RELEASE]
Why this matters: SB1042 is significant not because of the 10% ceiling but because it treats digital assets as an investable asset class for public pension systems. That is a category shift. New Hampshire’s HB 302 created a Bitcoin-only mandate; Texas’s SB 21 validated a full custody chain by routing $5M through BlackRock’s IBIT; SB1042 goes further by referencing the federal Strategic Bitcoin Reserve for storage, a state bill plugging directly into federal custody infrastructure. Every 2026 crypto regulation debate is about permission. Three states are already past it, building the operational plumbing for government-held digital assets before the BITCOIN Act reaches a vote.
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Franklin paid in its own token
Franklin Templeton acquired 250 Digital, a CoinFund spinoff with all of CoinFund’s liquid crypto strategies, to create a new unit called Franklin Crypto. The interesting part is the payment: Franklin used it’s BENJI tokens, the on-chain shares of its own U.S. Government Money Fund (FOBXX), yielding 3.58%, as deal currency. The deal closes Q2 2026, one week after Franklin partnered with Ondo Finance to tokenize five ETFs for 24/7 crypto wallet trading. [RELEASE]
Why this matters: This the first time a top-20 global asset manager has used a tokenized fund share to pay for a corporate acquisition.
Let’s unpack that: There are two ways to get blockchain infrastructure. You buy it, or you build it. Stripe paid $1.1 billion for Bridge. Mastercard paid $1.8 billion for BVNK. Franklin built its own. Benji runs on 10 public blockchains; it feeds into Canton Network’s collateral markets where HSBC, BNP Paribas, and Citadel Securities operate; it powers off-exchange collateral at Binance and enables stablecoin-to-MMF trading with Ripple and DBS. And now it works as deal currency. Crypto M&A hit $37 billion in 2025, but look at what every other major deal has in common: an incumbent paying billions for someone else’s plumbing. Franklin is the only one using its own. Issuance, settlement, collateral, distribution, corporate treasury, all on rails it built. Everyone else is still assembling.
Read our full CEO Notes👇
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Citadel wants a bank charter
EDX Markets applies for a national trust bank charter to provide institutional-only digital asset custody, settlement, and asset management under federal banking supervision. The exchange, backed by Citadel Securities, Fidelity Digital Assets, and Charles Schwab filed with the OCC on March 25 to charter EDX Trust, National Association as a de novo national trust bank in Chicago, requesting full fiduciary powers to serve institutional clients exclusively through electronic APIs. The proposed entity would provide fiduciary custody of digital assets and stablecoins, riskless principal trading, and end-of-day net settlement, all separated from EDX’s existing order-matching platform; no branches, no retail services, no proprietary trading, no deposit-taking. [RELEASE]
Why this matters: Think about who’s behind EDX. Citadel Securities processes over a third of all US retail equity trades. Fidelity runs one of the largest custody operations on Earth. Charles Schwab clears for millions of brokerage accounts. These aren’t crypto tourists. These are the firms that built equity market structure. And they’re telling the OCC: we want to bring that same architecture to digital assets. Separate the custody from the trading. Put a federal trust bank in the middle. Run it the way stocks already work. The OCC is listening. The OCC has conditionally approved five digital asset firms since December, received at least 18 charter applications in 2025, and finalized an April 1 rule expanding what trust banks are allowed to do; Coinbase, which filed its own application in October, was not among those approved. Meanwhile, the Bank Policy Institute, which represents 40 of the biggest US lenders (JPMorgan, Goldman Sachs, the usual names), is considering a lawsuit to block the entire charter wave. Citadel and Fidelity want the charter. JPMorgan’s lobby group wants to kill it. The custody war isn’t between crypto and banks anymore. It’s between banks.
Moody’s just priced bitcoin as collateral
Moody’s rates a $100 million bond backed entirely by Bitcoin, the first time a major credit agency has scored a bond where the only thing standing behind it is BTC. The bond is issued through New Hampshire’s state finance authority, but repayment comes solely from Bitcoin collateral, not taxpayer money. CleanSpark, a publicly traded Bitcoin miner, puts up $160 million in BTC (1.6x the bond’s value) held by BitGo; if Bitcoin’s price drops far enough, the whole thing gets liquidated automatically to pay investors back. Moody’s gave it a Ba2, two notches below investment grade, but rated it using the same framework it applies to traditional loan obligations. [RELEASE]
Why this matters: A major credit agency just published a working methodology for rating Bitcoin as bond collateral. Ba2 is speculative grade; the methodology is the real product. S&P got there first with Ledn’s BBB- Bitcoin-backed ABS in February, but that deal hit a 27% BTC drawdown and lost a quarter of its collateral to forced liquidation almost immediately. New Hampshire built toward this in steps: HB 302 authorized Bitcoin in the state treasury in May 2025, the BFA approved the bond in November, Moody’s rated it in March. Ba2 locks out pension funds, insurance general accounts, and most muni buyers, but Fitch has no comparable framework, and every conduit issuer in the country now has a template sitting on Moody’s website.
Other Signals
The US Labor Dept proposes Bitcoin in 401(k) plans. Link
Square enables Bitcoin payments for millions of merchants. Link
Senate Banking Committee to mark up the CLARITY Act in April. Link
S&P Dow Jones indices announce first tokenized index for onchain markets. Link
SoFi announces 24/7 banking hub that blends traditional cash with crypto. Link
Fed Vice Chair Barr calls for strong stablecoin oversight. Link
US Congress advances payment stablecoin framework. Link
StraitsX 40x stablecoin volume growth in SE Asia. Link
CoinShares begins trading on Nasdaq via SPAC. Link
HKMA Project Ensemble for wholesale CBDC. Link
Our CEO Notes this week
If you're building infrastructure, allocating capital, or pricing the shift to always-on markets, this is the briefing your competitors already read on Monday.
That’s all for now, folks.
PRO Readers: Read our alpha insights below!
– Marc & Team
