To Whom it May Concern:
The Bank Policy Institute[1] and American Bankers Association[2] appreciate the opportunity to respond to the notice and request for comment issued by the Federal Deposit Insurance Corporation regarding proposed reporting forms that permitted payment stablecoin issuers (“PPSIs”) subject to the FDIC’s jurisdiction would be required to submit.[3]
In all aspects of rulemaking under the GENIUS Act, it will be critical for the FDIC and other primary Federal payment stablecoin regulators to preserve the benefits of payment stablecoins for their intended use in payments and settlements, without causing undue and unnecessary risks for consumers, other stablecoin holders or users, competition, credit availability, illicit finance, or financial stability. These principles apply equally to the design of reporting forms, which help to monitor compliance with regulatory requirements, facilitate effective supervision of PPSIs, and promote transparency into the financial condition of PPSIs. The FDIC should adopt the following recommendations to ensure its reporting forms for FDIC-supervised PPSIs better serve these purposes.
I. To give the public appropriate opportunity to comment, the FDIC should propose PPSI reporting forms only after it has finalized its substantive regulatory requirements for PPSIs.
The FDIC should finalize its substantive requirements for PPSIs and repropose the reporting forms to reflect the regulatory requirements it has adopted. There are significant changes that the FDIC should make to aspects of its substantive rules that would materially change the reporting forms. The public should have the opportunity to comment on proposed reporting forms that align with the underlying substantive regulations.
To read the full comment letter, please click here, or click on the download button below.
[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.
[2] The American Bankers Association is the voice of the nation’s $26.1 trillion banking industry, which is composed of small, regional and large banks that together employ over 2 million people, safeguard $20.5 trillion in deposits and extend $13.7 trillion in loans.
[3] FDIC, Reporting Forms and Instructions Associated With Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers, 91 Fed. Reg. 45274 (July 20, 2026).
