The Securities Industry and Financial Markets Association (SIFMA) made several recommendations for the Office of the Comptroller of the Currency (OCC) in implementing the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act for the issuance of stablecoins by entities subject to OCC jurisdiction.
SIFMA, along with the SIFMA Asset Management Group (AMG), supports a framework for payment stablecoin activity and commends the OCC for its proposal that recognizes the nature of the payment stablecoin ecosystem and the need for supervisory standards.
However, SIFMA officials said that the proposal would benefit from additional clarification, more targeted calibration, and other tweaks. Overall, SIFMA recommends that the same risk, same activity, and same regulatory outcome principle apply across issuer types; that the final rule provides clear standards for compliance and supervision while preserving room for market development; and that the OCC coordinate closely with the other GENIUS Act regulatory agencies and, where appropriate, with the SEC and CFTC.
“SIFMA welcomes the OCC’s proposal as a strong foundation for the federal regulation of payment stablecoins,” Peter Ryan, SIFMA managing director, head of digital assets and international prudential policy, said. “Given the projected scale of payment stablecoin issuance and its potential interaction with short-dated Treasury and repo markets, careful calibration of the final rule will be essential to support both safe and sound issuance and the continued resilience of U.S. capital markets.”
SIFMA’s recommendations include the following:
- The OCC should clarify the scope of the proposal’s application to covered entities and the allocation of regulatory responsibility across issuers, custodians, distributors, wallet providers, and payment intermediaries. The OCC should also provide clear guidance on identifying compliant payment stablecoins.
- The definition of “distributed ledger” should not inadvertently exclude permissioned or private ledger architectures.
- The OCC should calibrate affiliate transaction restrictions to issuer organizational form to avoid both duplicative obligations for bank-affiliated permitted payment stablecoin issuers (PPSIs) and insufficient specificity for nonbank PPSIs.
- SIFMA recommends removing assets held in custody from the proposed 40 percent single-institution concentration limit, increasing the weighted average maturity limit from 20 days to 60 days to align with the statutory 93-day maturity ceiling and the framework applicable to government money market funds.
- The OCC should remove the automatic seven-day redemption extension triggered by a 10 percent outflow threshold, which risks encouraging preemptive redemptions and worsening run dynamics.
- The OCC should clarify the interaction of the proposal’s custody and control concepts with existing legal and regulatory frameworks—including broker-dealer custody standards.
- The OCC should clarify the expected insolvency and bankruptcy treatment of reserves, the capital treatment of third-party payment stablecoin exposures held by banking organizations, and the application of the operational backstop to rapidly scaling and de novo issuers.
SIFMA is a trade association for broker-dealers, investment banks and asset managers.