Letter to FinCEN and the Federal Banking Agencies on Customer Identification Program Obligations for Permitted Payment Stablecoin Issuers

Dear Acting Director Casanova, Comptroller Gould, Chairman Warsh, and Chairman Hill:

The American Bankers Association (ABA) welcomes the opportunity to comment on the notice of proposed rulemaking (NPRM) issued by Treasury's Financial Crimes Enforcement Network, along with the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA) on June 22, 2026. The proposed rule is intended to implement the directives in the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) to treat permitted payment stablecoin issuers (PPSIs) as financial institutions under the Bank Secrecy Act (BSA) and for PPSIs to maintain an effective customer identification program (CIP). Banks and other types of financial institutions are already required to maintain formal CIP programs—although many digital asset service providers are not.

I. Summary

We commend FinCEN and the federal banking agencies for jointly proposing CIP requirements for PPSIs to promote regulatory consistency and a uniform standard. ABA supports requiring PPSIs to implement CIP programs like banks and many other financial institutions but recommends three changes prior to finalization. First, PPSI CIP obligations should not be limited to customers with whom PPSIs have a "formal relationship," a banking concept used in banks' 2003 CIP rule designed to exclude de minimis transactions that does not accurately PPSI business operations or activities and could exclude significant primary market activity the rule should capture. Instead, the rule should state that purchasing or redeeming a payment stablecoin directly from the issuing PPSI first requires opening an account with the PPSI and triggers CIP requirements. Second, illicit finance risk must be managed in both primary and secondary markets. Requiring prospective customers to open accounts with the PPSI before direct purchase from or redemption by the PPSI would allow PPSIs to reject customers who decline to provide CIP information, provide obviously fraudulent information, or otherwise fail the PPSI's onboarding standards. Furthermore, to avoid critical gaps that could facilitate potentially illicit activity, secondary market actors including exchanges and other virtual asset service providers must be subject to equivalent regulation and examination. Third, CIP collection requirements should remain uniform across financial institutions. Adding an unexplained "date of formation" requirement for legal entity customers creates uncertainty and could interfere with PPSIs' ability to rely on CIP collected by other financial institutions, including their own parent banks.

Download the comment letter to read the full text.