Joint Letter Requesting an Extension of Comment Period on the OCC's GENIUS Act Implementation NPRM

Dear Office of Chief Counsel:

The American Bankers Association, the Bank Policy Institute, the Consumer Bankers Association, and the Independent Community Bankers of America request that the Office of the Comptroller of the Currency ("OCC") extend the deadline for public comments in response to the Notice of Proposed Rulemaking referenced above (the "GENIUS Act NPR") by 60 days, for a total comment period of 120 days after publication in the Federal Register.

We appreciate the OCC’s proposal, which would help provide regulatory clarity regarding the implementation of the GENIUS Act. However, while we are appreciative of the opportunity to comment, the 60-day comment period is not sufficient to effectively examine and comment on 376 pages of material, over 200 questions, and more than 1,000 sub-questions.

The NPR could have serious and significant implications for financial institutions and the financial system more broadly. Our associations, representing thousands of financial institutions, need additional time to properly analyze the NPR and provide useful input. We also ask that the OCC coordinate closely with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration to ensure that requirements for permitted payment stablecoin issuers are substantially similar and appropriately rigorous across the primary Federal payment stablecoin regulators.

Download the joint comment letter to read the full text.