Ladies and Gentlemen:
The Bank Policy Institute[1] and The Clearing House Association[2] appreciate the opportunity to comment on the Federal Deposit Insurance Corporation’s proposed rule to implement appropriate Bank Secrecy Act (“BSA”) and sanctions compliance standards applicable to FDIC-supervised permitted payment stablecoin issuers (“PPSIs”).[3] This proposal is an important component of the broader framework implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”) that, in combination with the numerous other rules the GENIUS Act requires federal agencies to promulgate, will affect both the consistency of the federal PPSI framework and the integrity of the U.S. financial system.
As we have noted in prior comment letters responding to different regulatory proposals under the GENIUS Act, the Associations remain concerned that commenters have not been given a meaningful opportunity to evaluate the numerous interdependent proposals implementing the GENIUS Act either individually or comprehensively. We have previously requested extensions of the comment periods for various proposals to implement the GENIUS Act, which generally have had insufficient 60-day comment periods and overlapping comment deadlines.[4] The rulemakings to implement the GENIUS Act represent an interrelated body of regulatory work of extraordinary scope and complexity, establishing a new federal regulatory framework to govern payment stablecoins. A fragmented comment process with staggered deadlines across numerous interdependent proposals issued by several different agencies undermines the agencies’ own stated goal of ensuring regulatory consistency across the GENIUS Act implementation framework. It also raises questions about whether the agencies have adequately coordinated in promulgating these rules, as required by section 4(h)(2), and encouraged by section 13(b), of the GENIUS Act.[5]
Therefore, we note that our comment reflects the best analysis of the proposal we have been able to conduct during an inappropriately short and fragmented comment period. We reserve the right to amend our comments on the proposal as other agencies propose and finalize regulations that have direct bearing on this one, and vice versa, and we reiterate our call for the federal payment stablecoin regulators and other relevant agencies to coordinate their rulemakings in terms of both substance and process before finalizing any rules to avoid unintended policy consequences, unworkable or incongruous requirements, and regulatory arbitrage opportunities. The agencies should repropose for comment any aspects of their respective proposals that are inconsistent or in conflict with one another to ensure that the comprehensive regulatory framework implementing the GENIUS Act is appropriately robust, transparent and consistent across the various agencies with rule-writing authority under the statute.
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. BPI 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 Clearing House Association L.L.C., the country’s oldest banking trade association, is a nonpartisan organization that provides informed advocacy and thought leadership on critical payments-related issues. Its sister company, The Clearing House Payments Company L.L.C., owns and operates core payments system infrastructure in the United States, clearing and settling more than $2 trillion every business day.
[3] 91 Fed. Reg. 34, 171 (June 5, 2026).
[4] See BPI, American Bankers Association, Consumer Bankers Association, and Independent Community Bankers of America, Joint Letter Requesting an Extension of Comment Period on the GENIUS Act Notice of Proposed Rulemakings (Apr. 21, 2026), https://www.aba.com/advocacy/policy-analysis/extension-request-genius-act-nprms.
[5] 12 U.S.C. §§ 5903(h)(2); 5913(b).
