Extension Request to the Treasury on the GENIUS Act ANPRM

Dear Counselors:

We appreciate Treasury's leadership in advancing regulatory clarity for payment stablecoins and its commitment to public engagement. On behalf of the American Bankers Association, along with American's Credit Unions, Bank Policy Institute, Community Development Bankers Association, Consumer Bankers Association, Independent Community Bankers Association, National Bankers Association, and The Clearing House Association, we respectfully request an extension of the 30-day comment period for the Advance Notice of Proposed Rulemaking (ANPRM) issued by the Department of the Treasury regarding the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act.

The ANPRM poses nearly 60 foundational questions across a wide range of complex and interrelated topics, including regulatory clarity, issuer requirements, illicit finance, foreign comparability, taxation, insurance, and economic data. These questions touch on core elements of a future regulatory framework for payment stablecoins and digital asset service providers, and will have significant implications for financial institutions, consumers, and the broader digital asset ecosystem.

Given the breadth and depth of the issues raised—and the importance of providing Treasury with thoughtful, data-informed, and actionable feedback—we believe that a 30-day comment period is insufficient. A longer comment period would allow stakeholders to engage with member institutions and experts to gather meaningful input.

We respectfully request that Treasury extend the comment period by an additional 60 days, for a total of 90 days from the date of publication in the Federal Register. This extension would ensure that Treasury receives comprehensive and well-considered responses that support the development of a robust and effective regulatory framework under the GENIUS Act.

Thank you for your consideration of this request. We look forward to engaging on this important topic.

Sincerely,

American Bankers Association
America's Credit Unions
Bank Policy Institute
Community Development Bankers Association
Consumer Bankers Association
Independent Community Bankers Association
National Bankers Association
The Clearing House Association