FTA Comment Letter on OCC Genius Act Implementation
WASHINGTON, D.C. – The Financial Technology Association (FTA) welcomed the Office of the Comptroller of the Currency’s (“OCC”) efforts to establish a clear regulatory framework for payment stablecoins that supports innovation while appropriately managing risks in a comment letter submitted in response to the OCC’s Notice of Proposed Rulemaking implementing the GENIUS Act.
“As stablecoins emerge as an important layer of payment infrastructure, a well-calibrated regulatory framework is essential to ensure these innovations can scale responsibly while enhancing competition and consumer choice,” wrote FTA President and CEO Penny Lee. “A clear federal framework also supports bringing these activities within a well-defined regulatory perimeter, strengthening oversight while enabling responsible innovation. Consistent with other payment-focused frameworks, requirements should be calibrated to the specific risks and activities involved, while facilitating innovation and competition that benefits end-users.”
FTA offered the following recommendations as the OCC works to implement the Genius Act:
Adhere to the statutory language of the GENIUS Act by limiting the yield prohibition to payments made by issuers directly to holders, and avoid overbroad interpretations that extend it to third parties or standard commercial arrangements.
Preserve the par value of stablecoins by prohibiting issuer-imposed fees that reduce redemption value below nominal value, while allowing fees for separately contracted ancillary services.
Adopt a risk-based approach to reserve concentration, avoiding rigid caps and supporting clearly defined safe harbors that reduce risk.
Ensure the final rules are interpretively consistent with the OCC’s March 2026 final rule regarding nationally chartered trust entities.
Promote market transparency and compliance through a publicly accessible registry of authorized PPSIs.
The Financial Technology Association (FTA) is a network of fintech industry leaders shaping the future of finance. We champion financial innovation and advocate for policies that expand competition, access, and opportunity.
FTA Comment Letter on OCC Genius Act Implementation
WASHINGTON, D.C. – The Financial Technology Association (FTA) welcomed the Office of the Comptroller of the Currency’s (“OCC”) efforts to establish a clear regulatory framework for payment stablecoins that supports innovation while appropriately managing risks in a comment letter submitted in response to the OCC’s Notice of Proposed Rulemaking implementing the GENIUS Act.
“As stablecoins emerge as an important layer of payment infrastructure, a well-calibrated regulatory framework is essential to ensure these innovations can scale responsibly while enhancing competition and consumer choice,” wrote FTA President and CEO Penny Lee. “A clear federal framework also supports bringing these activities within a well-defined regulatory perimeter, strengthening oversight while enabling responsible innovation. Consistent with other payment-focused frameworks, requirements should be calibrated to the specific risks and activities involved, while facilitating innovation and competition that benefits end-users.”
FTA offered the following recommendations as the OCC works to implement the Genius Act:
Read the full comment letter here.
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The Financial Technology Association (FTA) is a network of fintech industry leaders shaping the future of finance. We champion financial innovation and advocate for policies that expand competition, access, and opportunity.