U.S. Department of the Treasury Attention: Office of General Counsel 1500 Pennsylvania Avenue NW Washington, DC 20220
Re: GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale
The Conference of State Bank Supervisors (“CSBS”)1, the Money Transmitter Regulators Association (MTRA), the National Association of State Credit Union Supervisors (“NASCUS”)2, and the National Conference of State Legislatures (“NCSL”) (collectively “the state organizations”) provide the following comments on the Department of the Treasury’s (“Treasury”) notice of proposed rulemaking implementing GENIUS Act prohibitions and limitations on payment stablecoin issuance, as well as on the offer and sale of payment stablecoins by a digital asset service provider (“DASP”).3 The proposal would also establish a safe harbor for payment stablecoin issuers seeking approval from a federal payment stablecoin regulator as of the GENIUS Act effective date (“effective date”).
Treasury should implement safe harbors that permit payment stablecoin issuers to operate under qualifying state regimes as of the effective date.
Treasury should establish regulatory safe harbors that implement the GENIUS Act’s clear intent to preserve an important role for state regulation of payment stablecoin issuers. From their inception, U.S. dollar-denominated stablecoin markets have developed and grown under the regulation and supervision of states. Until the effective date, stablecoin issuance by United States companies remains primarily licensed and regulated by states. For Treasury to finalize this proposal in a way that reflects Congressional intent, it must allow issuers to choose from the full range of regimes contemplated by the GENIUS Act, including those reflecting this depth of state experience, without the risk of business disruption or uncertainty.
CSBS is the nationwide organization of state banking and financial regulators from all 50 states, the District of Columbia, and the U.S. territories. The views presented in this letter may not reflect the policy of individual states.
NASCUS is the professional association of the nation’s forty-five state and territorial credit union regulatory agencies that charter and supervise over 1,800 state credit unions. NASCUS membership includes state regulatory agencies, state chartered and federally chartered credit unions, and other important stakeholders in the state system. State-chartered credit unions hold approximately half of the $2.4 trillion assets in the credit union system and are proud to represent nearly half of the 145 million members. The remaining six states lack state-chartered credit unions.
U.S. Department of the Treasury
Attention: Office of General Counsel
1500 Pennsylvania Avenue NW
Washington, DC 20220
Re: GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale
The Conference of State Bank Supervisors (“CSBS”)1, the Money Transmitter Regulators Association (MTRA), the National Association of State Credit Union Supervisors (“NASCUS”)2, and the National Conference of State Legislatures (“NCSL”) (collectively “the state organizations”) provide the following comments on the Department of the Treasury’s (“Treasury”) notice of proposed rulemaking implementing GENIUS Act prohibitions and limitations on payment stablecoin issuance, as well as on the offer and sale of payment stablecoins by a digital asset service provider (“DASP”).3 The proposal would also establish a safe harbor for payment stablecoin issuers seeking approval from a federal payment stablecoin regulator as of the GENIUS Act effective date (“effective date”).
Treasury should establish regulatory safe harbors that implement the GENIUS Act’s clear intent to preserve an important role for state regulation of payment stablecoin issuers. From their inception, U.S. dollar-denominated stablecoin markets have developed and grown under the regulation and supervision of states. Until the effective date, stablecoin issuance by United States companies remains primarily licensed and regulated by states. For Treasury to finalize this proposal in a way that reflects Congressional intent, it must allow issuers to choose from the full range of regimes contemplated by the GENIUS Act, including those reflecting this depth of state experience, without the risk of business disruption or uncertainty.
Read the full comment letter.
CSBS is the nationwide organization of state banking and financial regulators from all 50 states, the District of Columbia, and the U.S. territories. The views presented in this letter may not reflect the policy of individual states.
NASCUS is the professional association of the nation’s forty-five state and territorial credit union regulatory agencies that charter and supervise over 1,800 state credit unions. NASCUS membership includes state regulatory agencies, state chartered and federally chartered credit unions, and other important stakeholders in the state system. State-chartered credit unions hold approximately half of the $2.4 trillion assets in the credit union system and are proud to represent nearly half of the 145 million members. The remaining six states lack state-chartered credit unions.
Department of the Treasury, Notice of Proposed Rulemaking, GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale, 91 Fed. Reg. 53368 (Aug. 18, 2026) (hereinafter “GENIUS Act Section 3 Proposal”).