BPI and ABA Comment on OCC Permitted Payment Stablecoin Issuers Reporting Requirements - Bank Policy Institute
To Whom it May Concern:The Bank Policy Institute[1]and American Bankers Association[2]appreciate the opportunity to respond to the notice and request for comment issued by the Office of the Comptroller of the. . .
To Whom it May Concern:The Bank Policy Institute[1]and American Bankers Association[2]appreciate the opportunity to respond to the notice and request for comment issued by the Office of the Comptroller of the Currency regarding proposed reporting forms that permitted payment stablecoin issuers and foreign payment stablecoin issuers subject to the OCC’s jurisdiction would be required to complete. [3]In all aspects of rulemaking under the GENIUS Act, it will be critical for the OCC 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 OCC should adopt the following recommendations to ensure its reporting forms for OCC-supervised PPSIs and FPSIs better serve these purposes. To read the full comment letter, pleaseclick here, or click on the download button below. [1]The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. BPI produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues. [2]The American Bankers Association is the voice of the nation’s $26. 1 trillion banking industry, which is composed of small, regional and large banks that together employ over 2 million people, safeguard $20. 5 trillion in deposits and extend $13. 7 trillion in loans. [3]OCC, Reporting Forms and Instructions for Permitted Payment Stablecoin Issuers Subject to the Jurisdiction of the Office of the Comptroller of the Currency, 91 Fed. Reg. 35795 (June 12, 2026). This comment letter uses the term PPSIs to include FPSIs, where appropriate.