_(Updated March 2026)_ |Feature|Florida (CS/CS/HB 175)|Wyoming (SEA-85 / Stable Token Act, as amended by SEA-44)| |---|---|---| |**Model Type**|Regulatory licensing framework for private issuers|State as direct issuer (public entity model)| |**Issuer**|Private companies licensed by the state|Wyoming Stable Token Commission, a body politic and corporate operating as an instrumentality of the state (W.S. 40-31-103)| |**Token Name**|No state token; regulates private tokens|Frontier Stable Token (FRNT); first implementation of the WYST framework| |**Statutory Definition**|"Payment stablecoin" = digital asset meant for payments with a stable value expectation|"A Wyoming stable token is a virtual currency representative of and redeemable for one (1) United States dollar held in trust by the state of Wyoming" (W.S. 40-31-104)| |**Primary Regulator**|Office of Financial Regulation (OFR); certifies substantial similarity to GENIUS Act regime|Wyoming Stable Token Commission; overseen by Wyoming Legislature's Select Committee on Blockchain; budget reports to Joint Appropriations Committee| |**Commission Composition**|N/A (regulatory body, not a commission)|7 members: Governor Mark Gordon (Chairman), State Auditor, State Treasurer, and four subject matter experts including former Circle General Counsel Flavia Naves| |**Federal Alignment**|Explicitly mirrors GENIUS Act (Pub. L. No. 119-27); OFR certifies "substantial similarity" to federal regime|Aligns with Executive Order 14178 "Strengthening American Leadership in Digital Financial Technology"; predates GENIUS Act but consistent with state-issued token category| |**Reserve Requirement**|1:1 backing; T-bills (93-day maturity or less) and reverse repos|Statute requires 102% overcollateralization per W.S. 40-31-106(b). Permitted assets: cash, U.S. Treasury securities (maturity 365 days or less), and Treasury repurchase agreements (term 30 days or less)| |**Reserve Manager / Custodian**|Not specified in legislation; issuer's choice|Franklin Templeton manages reserves; Fiduciary Trust Company International (Franklin Templeton affiliate) serves as custodian| |**Reserve Attestation**|Not specified in legislation|Monthly attestation reports by The Network Firm (independent CPA); first report published November 17, 2025| |**Blockchain Deployment**|Not specified; issuer's choice|FRNT deployed on 7 interoperable blockchains: Arbitrum, Avalanche, Base, Ethereum, Optimism, Polygon, and Solana; candidate blockchains under quarterly review include Aptos, Hedera, Sei, Stellar, and Sui| |**Technology Architecture**|Not specified|LayerZero OFT Standard for multichain issuance without bridges; Fireblocks ERC20F for role-based permissions; Wyoming operates its own decentralized verifier network (DVN)| |**Securities Classification**|Qualifying payment stablecoins explicitly NOT securities under Florida law|Not addressed as a securities question; state issuer framework operates outside typical securities analysis| |**AML/KYC**|Integrated into Florida's Control of Money Laundering in Money Services Business Act; wallet screening required|KYC/AML handled entirely by LSPs via "Know Your Business" compliance review before onboarding; Commission does not interact directly with end users| |**Distribution Model**|Issuers deal directly with consumers/businesses under OFR license|LSP-only model per Reserves Management and Token Management Rules; Wyoming does not sell directly to the public| |**Active Distribution Partners**|Not yet live|Kraken (Wyoming-domiciled SPDI); Rain (Visa-powered payment card platform on Avalanche); Stargate for cross-chain transfers| |**Pilot Programs**|State pilot (via [SB 1568](https://legiscan.com/FL/text/S1568/id/3387115)) for accepting stablecoins for government fees/taxes|Pilots conducted with Cattleproof, Fundora, Hashfire (automated vendor payments), and Wyopay; tested disaster-response payment use cases| |**Federal Oversight Trigger**|Issuer must notify OFR and transition to OCC oversight or halt new issuance if circulation exceeds $10B|No threshold; Wyoming sovereign entity status enables single issuance globally| |**Interest/Yield to Holders**|Prohibited if banned under federal law (GENIUS Act deference)|Current regulations prevent FRNT from offering yield to token holders; officials exploring this within compliance frameworks| |**Revenue Model**|State collects licensing/regulatory fees from issuers|Interest income on reserves beyond 102% overcollateralization transfers to state school foundation fund; Commission projects breakeven Q1 2027 (base case), returns to state beginning Q2 2028| |**Interdiction / Enforcement**|Unlicensed issuance is a 3rd-degree felony; fines up to $250K or 2x transaction value (5x on repeat)|Token Management Rules define "Lawful Legal Directives" for freeze/seize; interdiction must be downstream of a lawful court order; deny-lists built into ERC20F smart contract logic| |**Privacy**|[CS/CS/SB 1440](https://www.flsenate.gov/Session/Bill/2026/1440) (companion bill) protects issuer trade secrets and non-public OFR data|Commission assessing zero-knowledge proofs and homomorphic encryption to obfuscate on-chain data while preserving compliance visibility| |**CBDC Stance**|Not addressed|Wyoming passed [HB0264](https://www.wyoleg.gov/Legislation/2025/HB0264) (2025) prohibiting state agencies from interacting with a CBDC; FRNT explicitly distinguished as not a CBDC| |**Budget / Funding**|OFR funded through state appropriations and regulatory fees|Total allocation of $6.0M due back to General Fund; less than $2.0M deployed in 39 months; proposed 2026 amendment (26LSO-0057) would allow Commission to pay operational expenses from interest income before overcollateralization threshold| |**Interstate Cooperation**|Not addressed|Director Apollo reports outreach from over a dozen states and territories; North Dakota and Nebraska have followed with their own state-issued token efforts| |**Effective Date / Status**|Awaiting DeSantis signature; effective October 1, 2026|FRNT publicly available on Kraken as of January 7, 2026; statute in force since March 2023| --- ## Related Legislation Index ### Florida |Bill|Description|Link| |---|---|---| |CS/CS/HB 175 (2026)|Primary enrolled bill -- Payment Stablecoin framework|[flsenate.gov](https://www.flsenate.gov/Session/Bill/2026/175)| |SB 314 (2026)|Senate companion; laid on table in favor of HB 175|[flsenate.gov](https://www.flsenate.gov/Session/Bill/2026/314)| |CS/CS/SB 1440 (2026)|Confidentiality protections for OFR-collected data from digital asset businesses|[flsenate.gov](https://www.flsenate.gov/Session/Bill/2026/1440)| |SB 1568 (2026)|Florida Stablecoin Pilot Program; authorizes state to accept stablecoins for fees and taxes|[legiscan.com](https://legiscan.com/FL/text/S1568/id/3387115)| ### Wyoming |Bill|Description|Link| |---|---|---| |SF0127 / SEA-85 (2023)|Wyoming Stable Token Act -- created the Commission; initial $500K appropriation|[wyoleg.gov](https://wyoleg.gov/Legislation/2023/SF0127)| |SF0052 / SEA-44 (2024)|Amendments codifying permitted reserve asset types; granted Commission procurement authority; $5.8M appropriation|[wyoleg.gov](https://www.wyoleg.gov/Legislation/2024/SF0052)| |HB0264 (2025)|Central Bank Digital Currencies -- Prohibitions; bars Wyoming agencies from interacting with a CBDC|[wyoleg.gov](https://www.wyoleg.gov/Legislation/2025/HB0264)| |26LSO-0057 (2026, proposed)|Proposed amendment to W.S. 40-31-106(c); allows Commission to cover operational expenses from interest income before overcollateralization threshold is reached|[wyoleg.gov Select Committee minutes](https://wyoleg.gov/InterimCommittee/2025/S19-20250922830MeetingMinutes.pdf)| ### Federal Context | Bill / Rule | Description | Link | | ------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------- | | GENIUS Act (Pub. L. No. 119-27) | Guiding and Establishing National Innovation for U.S. Stablecoins Act; signed July 18, 2025; foundation for both FL and WY frameworks | [congress.gov](https://www.congress.gov/bill/119th-congress/senate-bill/394) | | CLARITY Act (proposed) | Clarifies SEC/CFTC jurisdiction over digital assets; stablecoin yield debate pending | [congress.gov](https://www.congress.gov/bill/119th-congress/house-bill/3633) | --- **Note:** The Wyoming Commission's full legislative archive, rules, attestation reports, and blockchain selection studies are publicly available at [stabletoken.wyo.gov](https://stabletoken.wyo.gov/). Florida's OFR rulemaking under HB 175 has not yet commenced pending the governor's signature.