Joint Trades Letter Requesting Comment Period Extension for GENIUS Act Proposals

Dear Vice Chair Bowman:

The undersigned trade associations (the "Associations") request that the Board of Governors of the Federal Reserve System (the "Board") extend by 60 days, to January 29, 2027, the comment periods for its two proposals implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the "GENIUS Act"): (i) Implementing the Federal Reserve Board’s Responsibilities Under the GENIUS Act (the "Prudential Proposal"); and (ii) Application Procedures for Board-Supervised Insured Depository Institutions Seeking Approval for a Subsidiary To Issue Payment Stablecoins (the “Applications Proposal,” and together, the “Proposals”). Both comment periods currently close November 30, 2026.

The Board modeled the Prudential Proposal on the proposal of the Office of the Comptroller of the Currency ("OCC"). It tags its questions to the corresponding OCC questions and invites comment on where its framework differs from those of the other agencies. The OCC proposal is the Board’s own benchmark for public comment. That benchmark is about to change. Comptroller Gould has stated that the OCC intends to finalize its rule by November 2026. Once final, the OCC rule, not its proposal, is the relevant comparison. Under the current schedule, commenters could have days, at most, to analyze it.

The Proposals are also substantial. The Prudential Proposal spans 104 pages of the Federal Register and covers permissible activities, reserves, redemption, risk management, supervision, capital, custody, tying, and State-qualified issuers. Further, the Applications Proposal depends on it. Applicants must show that a proposed subsidiary can meet the prudential requirements, and an interim capital standard applies until those requirements take effect. Evaluating both Proposals together, and against the OCC’s final rule, will take time and warrants careful analysis.

That analysis is essential to the coordination the GENIUS Act requires. The Act creates parallel paths to becoming a permitted payment stablecoin issuer ("PPSI"), each overseen by a different regulator. Material differences in requirements across payment stablecoin regulators would invite regulatory arbitrage, create an uneven playing field, and undermine the consistent framework Congress intended. The Associations have urged the Board to keep PPSI requirements substantially similar and appropriately rigorous across agencies. The Board can only do so with a comment record that addresses the OCC's final rule. The OCC's forthcoming final rule also underscores the need for the agencies to coordinate on the timing and effective dates of their final rules.

For these reasons, the Associations respectfully request that the Board extend the comment periods for both Proposals to January 29, 2027.

If you have any questions, please contact Kaye Lynch-Sparks at [email protected].

Sincerely,
The American Bankers Association
The Bank Policy Institute
Consumer Bankers Association
Independent Community Bankers of America