Global Digital Finance (GDF) submitted a response to the US Office of the Comptroller of the Currency’s (OCC) proposed rule implementing the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The response supports the OCC’s objective of establishing a clear and workable federal framework for payment stablecoin issuance while encouraging greater legal certainty, proportionality, and technology neutrality across the regime.
GDF’s submission focuses on ensuring that the framework appropriately accommodates the operational realities of digital asset and stablecoin markets, including non-US issuer structures, token-based governance arrangements, and the role of intermediaries within the broader stablecoin ecosystem. The response recommends targeted clarifications relating to definitions of “control,” “customer,” “acting in concert,” and “payment stablecoin,” as well as guidance on reserve custody, tokenized deposits, distributed ledger technologies, and the treatment of public blockchain data.
The submission also encourages the OCC to adopt a functional and risk-based approach that supports innovation and international competitiveness while maintaining robust prudential, AML, and consumer protection standards. Overall, GDF welcomes the opportunity to contribute to the implementation of the GENIUS Act and supports the development of a clear and globally interoperable framework for stablecoin regulation in the United States.
Submitted:
01/05/2026