Joint Letter to the OCC on Reporting Forms and Instructions for Permitted Payment Stablecoin Issuers

To Whom it May Concern:

The Bank Policy Institute and American Bankers Association appreciate the opportunity to respond to the notice and request for comment issued by the Office of the Comptroller of the Currency regarding proposed reporting forms that permitted payment stablecoin issuers and foreign payment stablecoin issuers subject to the OCC's jurisdiction would be required to complete.

In all aspects of rulemaking under the GENIUS Act, it will be critical for the OCC 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 OCC should adopt the following recommendations to ensure its reporting forms for OCC-supervised PPSIs and FPSIs better serve these purposes.

Download the joint comment letter to read the full text.