ART-582 · Verify-Rails · Reserve Verification Family
GENIUS Act Reserve-Disclosure Conformance Monitor
Checks a monthly reserve disclosure against two statute-derived GENIUS Act S.394 §4 requirements: 1:1 reserve coverage arithmetic and attestation presence/timeliness against the statutory monthly cadence. Verdict per requirement: MET / NOT_MET / INDETERMINATE. Cross-links: pre-issuance Reserve Attestation Pre-Check and the fuller Monthly Reserve Disclosure Checker (asset composition and dual-control certification, statute-restatement pending final rule).
GENIUS Act S.394 §4Narrowed scopeNo final implementing rule (as of 2026-08-07)
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Scope: two checks only, not a compliance certification
This monitor does not check permitted-asset composition. No final GENIUS Act implementing regulation exists as of 2026-08-07 to check the reserve-asset list against (every OCC/FDIC/Treasury/FinCEN/NCUA instrument remains NPRM/ANPRM, and the statutory 2026-07-18 rulemaking deadline was missed). It checks only 1:1 coverage arithmetic and attestation presence/timeliness, both derivable directly from statute. A MET verdict is never "compliance certified" language, and all thresholds should be re-verified against final rule text once one publishes.
KEY DATES: GENIUS Act signed 18 Jul 2025 · effective date on or before 18 Jan 2027 (earlier if final implementing rules publish first, 120 days after) · statutory rulemaking deadline 18 Jul 2026 was missed, no final rule exists as of 2026-08-07 · monthly reserve reports required for licensed issuers.
⚠ DECISION-SUPPORT DRAFT. Not a filing or legal advice, and never "compliance certified" language. Checks two statute-derived requirements only; permitted-asset composition is out of scope pending final rule text. Re-verify against GENIUS Act S.394 final-rule text once one publishes.