Policy
CSBS supports state regulators in advancing the system of state financial supervision to promote safety, soundness, consumer protection, and economic growth, while fostering innovative, responsive supervision. The Policy Section outlines CSBS’s positions on legislation, regulations, and guidance to advance these objectives. These positions may not reflect those of individual states.
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Treasury’s Substantially Similar Principles for State Stablecoin Regimes Need Recalibration
The GENIUS Act recognized the states’ foundational role in the stablecoin market and directed Treasury to set principles for state regimes to be substantially similar to the federal framework — not identical.
OCC Stablecoin Rules Must Address Issuer Risks and Protect Consumers
The OCC should limit issuer activities consistent with the GENIUS Act and establish capital standards that address the heightened risks posed by digital asset service provider activities.
Agencies’ Capital Proposals Much Advanced but Warrant Further Improvements
CSBS supports the goal of enhancing the risk sensitivity, consistency, and transparency of the risk-based capital framework, but important adjustments are necessary to promote a level playing field between large and small banking organizations.
The OCC Overreaches with State Escrow Preemption
The OCC’s preemption of state interest-on-escrow laws erodes 50 years of precedent designed to protect consumers.
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Policy Statements
Access all testimony, comment letters, and policy letters sent by CSBS.
Networked Supervision
A supervisory approach that produces highly-skilled examiners, a more streamlined and efficient compliance process, and a safer consumer experience.
Cooperative Agreements
State Regulators have cooperative agreements with one another, with federal agencies, and with other state representative agencies. You can find all of these agreements here.