The RCA Briefing — Issue 0041

25 Aug 2026

Stablecoin files are denser. They are not interchangeable.

1. 01 · The Policy Shift

   No new federal US stablecoin text this week — state and MiCA files still drive the desk

   In the absence of a commenced comprehensive US federal stablecoin statute, RCA's live primary sources remain NYDFS trust supervision, MiCA EMT authorisation, and issuer attestations. Those three artefacts continue to be conflated in secondary coverage.

2. 02 · Why It Matters

   Practical impact

   A payments firm, an exchange or a fund administrator that treats 'NYDFS', 'MiCA EMT' and 'attested reserves' as synonyms will mis-specify controls. Redemption rights and insolvency language still have to be read in the terms, not inferred from the licence.

3. 03 · Issuer Watch

   Attestation as-of dates remain the most commonly over-read field

   Tether's latest published reserves attestation is a dated agreed-upon procedures report. It is Tier 2 evidence of that exercise. It is not a statutory audit of the issuing entity and not an EU EMT authorisation.

   Open Tether in the registry

4. 04 · Data Watch

   Five USD/EUR issuers now have at least one Tier 1 supervisory artefact in the RCA file

   Circle (EU EMT path), Paxos (NYDFS), SG-FORGE, Ripple/RLUSD (NYDFS-related public materials) and comparable bank-affiliated euro tokens. This is a count of artefacts, not a ranking of tokens.

5. 05 · The Source

   Circle EU EMT materials / ACPR path for USDC

   Tier 2VerifiedEU / France

   Circle Internet Financial Europe — EMT white paper and ACPR authorisation materials for USDC

   Circle / ACPR/1 Jul 2024/RCA review 25 Aug 2026

   Proves

   Circle has published MiCA EMT materials for USDC through its EU entity and has been treated as an authorised EMT issuer under the French competent authority process.

   Does not prove

   The treatment of USDC outside the EU, the composition of reserves at a future date, or that USDC is a deposit or e-money in every jurisdiction.