The Bank Policy Institute filed two comment letters today on the OCC’s proposed payment stablecoin requirements.

• In a joint letter with The Clearing House Association, BPI expressed general support for the OCC’s AML/CFT approach, while offering policy recommendations that would promote clarity in the framework.
• In a standalone letter, BPI reiterated suggestions it made to the OCC in response to its March 2026 proposal to establish requirements for stablecoin issuers under its jurisdiction. The standalone letter urged regulators to clarify consumer protection requirements for stablecoin issuers, recognize fraud risks more explicitly and strengthen liquidity safeguards.

“Strong AML/CFT requirements for stablecoin issuers are a crucial safeguard for consumers and the financial system, especially given cryptocurrency’s role as a global money laundering tool. As multiple federal agencies implement the GENIUS Act framework for stablecoin oversight, it’s critical that they coordinate their efforts and that the public have ample opportunity to comment on how the framework takes shape.” – BPI and The Clearing House Association

• BPI and The Clearing House Association expressed general support for the OCC’s proposal that stablecoin issuers under its jurisdiction must abide by the obligations established by FinCEN and OFAC in their joint proposal on payment stablecoin issuers. BPI and The Clearing House Association previously recommended that FinCEN and OFAC clarify certain aspects of that proposed rule and initiate a rulemaking to close regulatory gaps in AML/CFT and sanctions compliance obligations for stablecoin secondary-market actors.
• BPI and The Clearing House Association support the proposed consultation requirement with FinCEN regarding enforcement actions or significant AML/CFT supervisory actions. BPI and The Clearing House Association previously expressed support for a similar consultation requirement proposed by FinCEN, as well as jointly by the OCC, the NCUA and the FDIC, in their AML/CFT Program Proposal response.
• BPI and The Clearing House Association generally support the OCC’s proposed standard for AML/CFT enforcement and significant supervisory actions for payment stablecoin issuers. The proposal provides that PPSIs would not be subject to such actions absent a significant or systemic failure to implement an effective AML/CFT program. BPI and The Clearing House Association supported a similar standard for financial institutions in their AML/CFT Program proposal response.

In a standalone letter responding to questions in the OCC proposal about other non-AML/CFT supervisory issues, BPI reiterated several of the recommendations it made in response to the OCC and FDIC’s respective proposed rules governing stablecoin operations, including that the OCC should:

• Coordinate with other federal regulators to clarify the consumer protection requirements that apply to payment stablecoin issuers. Consumer protection laws and their application to stablecoin issuers are unaddressed in the GENIUS Act. For example, it is not clear whether Regulation E, which governs fund transfers, or Gramm-Leach-Bliley Act privacy standards apply to payment stablecoins. Clarifying such obligations is crucial for fraud disputes and other issues affecting consumers.
• Require payment stablecoin issuers to address fraud risks expressly in their risk management frameworks.
• Require payment stablecoin issuers to maintain consistent liquidity standards. They should also require stablecoin issuers to account for surges in redemption requests in their risk management frameworks and through mandatory stress tests. The FDIC’s proposed approach to redemption in stress is less conducive to run dynamics than the OCC’s approach, BPI noted in the letter.

Both letters urged the OCC to allow the public ample time to comment, expressing concern that the comment period on this proposal was too short. The letters also flagged the complexity of multiple interconnected proposals implementing the GENIUS Act, which may be challenging for commenters to digest, and highlighted the importance of coordination across the agencies tasked with writing rules under the GENIUS Act.

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About Bank Policy Institute
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. The Institute 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.

About The Clearing House Association
The Clearing House Association L.L.C., the country’s oldest banking trade association, is a nonpartisan organization that provides informed advocacy and thought leadership on critical payments-related issues. Its sister company, The Clearing House Payments Company L.L.C., owns and operates core payments system infrastructure in the U.S., clearing and settling more than $2 trillion each day.