One year ago today, the GENIUS Act was signed. Every implementing rule was due. Zero were issued. The statutory deadline was yesterday— a Saturday. The Federal Register doesn’t publish on weekends, and a rule isn’t final until it’s published there. So the last day this could actually have happened was Friday. Nothing came. Here’s what’s documented: 1. The OCC’s framework — proposed 12 CFR Part 15, issued February 25 — is still a proposal. 376 pages, 199 numbered questions for comment. Nothing in it binds anyone. 2. That proposal deliberately excluded BSA, AML, and OFAC sanctions. The OCC carved them out to a separate rulemaking “in coordination with the Department of the Treasury.” 3. That separate OCC BSA proposal didn’t arrive until June 22 — with a 30-day comment window. 4. The joint customer identification proposal published the same week with a 60-day window. Comments run into late August. You cannot close a rulemaking while its own comment period is still open — that’s basic notice-and-comment law, not a scheduling preference. 5. The OCC’s own weekly and quarterly reporting forms remain out for comment through August 11. The forms issuers must file don’t exist yet. 6. The Federal Reserve never issued a standalone prudential proposal at all. State member banks issuing stablecoins currently have no framework. 7. Treasury proposed its “substantially similar” state rule April 3. Comments closed June 2. No final rule. No state regime certified. 8. No foreign regime has been declared comparable. That determination requires a unanimous recommendation from the Stablecoin Certification Review Committee — Treasury Secretary, Fed Chair, FDIC Chair. The reciprocity deadline isn’t until July 18, 2027. 9. The statute carries no penalty for missing the 18th deadline. Congress wrote a date, not a consequence. No fallback provision, no default rule, no enforcement trigger. Another deadline missed. 10. The effective date is now fixed: January 18, 2027. **The Act takes effect on the earlier of 18 months from enactment or 120 days after final rules.** With no final rules, the 120-day path is dead. The backstop is all that’s left. Here’s what we can infer: The agencies made peace with this in June. You don’t open comment windows closing in August if you intend to finalize in July. The miss was a decision, not a failure. And a delay is never neutral. It just moves where the decisions get made. RULEMAKING IS PUBLIC. Comment periods, dockets, published text, everyone reads the same page. LICENSING IS NOT. Charters, trust bank approvals, master account applications — those move through supervisory discretion, case by case, on no published timeline. Every month the rulebook stays unwritten is a month the perimeter gets drawn one approval at a time instead. By the time Part 15 is final, the set of entities holding federal permission will already exist. The rule won’t create the field. It will ratify it. Watch what AND WHO gets approved, not what gets published.