Letter to the OCC on the Implementation of the GENIUS Act

Dear Chief Counsel:

The American Bankers Association respectfully submits this letter to supplement its comment of May 1, 2026, on the OCC's notice of proposed rulemaking implementing the GENIUS Act, and to transmit for the OCC's consideration ABA’s comment letter on the FDIC’s parallel proposed rulemaking (RIN 3064-AG19), enclosed as Attachment A. 

We share the FDIC letter with the OCC because it addresses matters of interagency coordination that bear directly on the OCC’s rulemaking and on the cohesion of the framework that the primary Federal payment stablecoin regulators are constructing together. The enclosed letter also incorporates ABA’s OCC comment as its own Appendix A; transmitting it here places ABA's full set of positions before each agency as the rulemakings advance toward finalization. 

We respectfully ask the OCC to give weight to the following; each developed more fully in the enclosed letter.

Download the letter to read the full text.