Analysis

The CLARITY Act faces a cloture vote it will likely lose. But Circle, Revolut, OpenReserve, and a 21-bank consortium have already mapped their buildouts onto OCC charters and GENIUS Act authority – and the January 2027 enforcement cliff is the only deadline that matters.

The CLARITY Act is currently functioning as a legislative elevator stuck between floors. A cloture vote is set for September 15 at 2:15pm ET, and the arithmetic is unforgiving: 60 votes required to advance, Republicans holding 53 seats, and only two Democrats – Senators Gallego and Alsobrooks – having crossed the aisle in committee. Polymarket bettors have priced the bill’s 2026 passage at 16%, down from 82% earlier this year. Galaxy Digital puts the odds…