Joint Trades Letter to the OCC on the Proposed Application and Registration Forms for Permitted Payment Stablecoin Issuers (PPSIs)

To Whom it May Concern:

The Bank Policy Institute, American Bankers Association, Consumer Bankers Association, and Independent Community Bankers of America appreciate the opportunity to respond to the notice and request for comment issued by the Office of the Comptroller of the Currency regarding applications for licensing or registration to issue payment stablecoins under the Guiding and Establishing National Innovation for U.S. Stablecoins Act.

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 application and registration forms, because the OCC will rely on information contained in these forms to evaluate whether the prospective permitted payment stablecoin issuer ("PPSI") or foreign payment stablecoin issuer ("FPSI") meets the requirements set forth in the GENIUS Act and OCC regulations to be codified at 12 C.F.R. § 15.30.

We therefore reiterate and incorporate by reference the recommendations with respect to OCC application processing in the BPI-CBA-Financial Services Forum comment letter responding to the OCC's proposal to implement the GENIUS Act for entities subject to OCC supervision.

Download the joint trades letter to read the full text.