Letter to the Treasury on the Notice of Proposed Rulemaking on Stablecoin Regulation

Dear Ms. Miller,

The American Bankers Association (ABA) appreciates the opportunity to respond to the Department of the Treasury's (Treasury) Notice of Proposed Rulemaking on GENIUS Act Broad-Based Principles for Determining Whether a State-Level Regulatory Regime Is Substantially Similar to the Federal Regulatory Framework (NPRM). ABA, along with other trade associations, previously requested an extension of the comment period. As an extension was not granted, we respectfully reserve the right to supplement the record with additional materials once the Office of the Comptroller of the Currency (OCC) finalizes its rule implementing the GENIUS Act for entities subject to the OCC's jurisdiction, on which this rulemaking hinges.

ABA has a number of recommendations for Treasury to consider that we believe would improve the effectiveness of its framework for evaluating state-level regulatory regimes. ABA's recommendations fall into two categories. Section I addresses revisions to the substantive standards proposed in this rulemaking. Section II addresses the absence of procedural rules governing how the Stablecoin Certification Review Committee (SCRC) will operate.

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