The bill created a $10 billion limit for non-depository trust institutions to be able to issue payment stablecoins. Once the issuer exceeds that amount, it must be “a depository institution that has been authorized as a national payment stablecoin issuer,” the bill’s text said. At present, the largest U.S.-based stablecoin issuer, Circle (with $33 billion in outstanding (USDC)), is not a depository trust institution. The next largest, Paxos, does have a limited purpose trust charter through the New York Department of Financial Services, though its market cap falls well below that $10 billion cutoff. A Senate staffer described the $10 billion limit as the approximate cutoff between a small community bank and a larger regional financial institution with systemic risk potential.