Ladies and Gentlemen:
The undersigned trade associations (the “Associations”)[1] appreciate the opportunity to comment on the notice of proposed rulemaking (the “NPR”) issued by the Office of the Comptroller of the Currency (the “OCC”) regarding the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”).[2]
We appreciate the OCC’s careful consideration of the regulations that it is required to issue under the GENIUS Act. As the NPR correctly acknowledges, the implementation of the GENIUS Act raises numerous significant policy questions. In particular, the way in which the GENIUS Act is implemented, and the prudential requirements that will apply to payment stablecoin issuers, could have significant effects on financial stability, credit creation, consumer protection and the broader economy. Changes and clarifications to the proposed rule are important to ensure the GENIUS Act is implemented in a manner that, as Congress envisioned, appropriately balances the benefits and innovative potential of payment stablecoins with the broader economic and consumer protection risks that these instruments may pose.
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[1] Please see Annex A for a description of the Associations.
[2] OCC, Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency, Notice of Proposed Rulemaking, 91 Fed. Reg. 10,202 (Mar. 2, 2026).
