Global Digital Finance (GDF) submitted a response to the New York State Department of Financial Services (NYDFS) consultation on proposed 23 NYCRR Part 202, which would codify New York’s regulatory framework for authorized payment stablecoin issuers.
GDF supports the development of a clear prudential framework for payment stablecoins, including robust requirements for reserve backing, redemption, governance, risk management, operational resilience, reporting and financial crime controls. The response emphasises, however, that implementation should preserve a meaningful state regulatory pathway while avoiding unnecessary duplication between New York, federal and international regimes.
The submission recommends an outcomes-based approach to state and federal equivalence under the GENIUS Act rather than requiring state rules to mirror federal requirements line by line. It also calls for proportionate requirements that reflect issuers’ size, activities and risk profiles, alongside safeguards to prevent evolving federal rules from creating automatic duplication or regulatory inconsistency.
Given the cross-border nature of stablecoins, GDF also highlights the importance of international regulatory interoperability. The response encourages recognition of comparable prudential outcomes where legally possible, clear allocation of regulatory responsibilities across issuers and intermediaries, and avoidance of requirements that unnecessarily fragment liquidity or require jurisdiction-specific token structures.
Overall, the submission calls for a clear, credible and prudentially sound framework that maintains high standards of protection while supporting regulatory coordination, proportionality and the interoperability and efficiency of stablecoins as payment and settlement infrastructure.
Submitted:
September 2026
