Joint Trades Letter to the FDIC on the proposed reporting forms for FDIC-supervised 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 Federal Deposit Insurance Corporation regarding proposed reporting forms that permitted payment stablecoin issuers ("PPSIs") subject to the FDIC's jurisdiction would be required to submit.

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

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