The implementation of the PACE Act and GENIUS framework allows non-bank payment companies like Dakota to bypass sponsor banks and plug directly into Federal Reserve payment rails (ACH, wires, FedNow) under OCC supervision. This shift enables stablecoin infrastructure providers to hold reserves and settle flows via federal trust charters rather than relying on traditional banking partners. The sentiment suggests a major architectural shift for fintechs like Circle, moving toward self-contained banking structures by 2027.