Letter Requesting the Extension of Comment Period on the FDIC's NPR re: Approval Requirements for Issuance of Payment Stablecoins

Dear Ms. Jones:

The American Bankers Association, the Bank Policy Institute, The Clearing House Association, the Consumer Bankers Association, and the Independent Community Bankers of America request that the FDIC extend the deadline for public comments on the Notice of Proposed Rulemaking referenced above (the "Approval Requirements NPR") by the later of (i) 60 days or (ii) 30 days after the issuance by the FDIC of an NPR to implement the capital, liquidity, risk management, and other requirements under section four of the GENIUS Act for permitted payment stablecoin issuers ("PPSIs") that are subsidiaries of insured depository institutions.

The Approval Requirements NPR would implement the application provisions of the GENIUS Act for FDIC-supervised depository institutions to issue payment stablecoins through a subsidiary. The NPR was released on December 16, 2025, and published in the Federal Register on December 19, 2025. Comments are due to the FDIC by February 17, 2026.

The FDIC has not yet issued a proposal to implement the capital, liquidity, risk management, and other prudential requirements, as required by section four of the GENIUS Act, that would apply to PPSIs that are subsidiaries of FDIC-supervised institutions. Our comments on the Approval Requirements NPR would be more comprehensive—and therefore more useful to the FDIC—if we could consider simultaneously the proposed substantive requirements that the FDIC would evaluate under this approval process.

In addition, the undersigned associations as well as other stakeholders involved in the digital asset ecosystem need sufficient time to consider how this NPR would interact with the GENIUS Act’s complex and novel regulatory framework for payment stablecoins. The Approval Requirements NPR is one of dozens of interrelated rulemakings required by Congress to implement the GENIUS Act. We appreciate the FDIC’s effort to undertake this rulemaking quickly, but this regulation and the related ones required to be issued by other agencies can effectively achieve Congress’ policy goals only if affected parties are given the opportunity to thoughtfully consider all required rulemakings applicable to payment stablecoins holistically.

For these reasons, we respectfully request an extension of the comment period as proposed above, which would better allow us and other interested members of the public to prepare carefully considered and well-informed comments on the Approval Requirements NPR.

We appreciate the opportunity to comment on the Approval Requirements NPR and your consideration of our request. If you have any questions, please contact Drew Ruben by email at [email protected].

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