Digital Asset Regulation
Position Summary
In July 2025, Congress enacted the GENIUS Act to establish a national framework for the regulation of payment stablecoins and their issuers. The act allows three types of permitted payment stablecoin issuers (PPSIs): a subsidiary of an insured depository institution, a federally qualified payment stablecoin issuer (supervised by the OCC), and a state qualified payment stablecoin issuer (supervised by the licensing state). A robust state pathway for payment stablecoin issuers is critical to maintain dynamic supervision of payment stablecoin issuers, better protect consumers who purchase stablecoins, and support innovation in this developing market.

Digital Asset Regulation News

Comment Letter

Digital Asset Market Structure Legislation

Download the Full Comment Letter [PDF] The Honorable Tim Scott Chairman Committee on Banking, Housing & Urban Affairs United States Senate Washington, DC 20510 The Honorable Elizabeth Warren Ranking Member Committee on Banking, Housing & Urban Affairs United States Senate Washington, DC 20510 Re: Digital Asset Market Structure Legislation Dear Chairman Scott and Ranking Member Warren: The Conference of State
January 14, 2026
Comment Letter

Guidance on Tokenized Deposits

Download the Full Comment Letter [PDF] The Honorable Travis Hill Acting Chairman Federal Deposit Insurance Corporation 550 17 th Street NW Washington, DC 20429 The Honorable Michelle W. Bowman Vice Chair for Supervision Board of Governors of the Federal Reserve System 20 th Street and Constitution Avenue NW Washington, DC 20551 The Honorable Jonathan Gould Comptroller of the Currency Office
November 4, 2025
Comment Letter

Genius Act Implementation

Download the Full Comment Letter [PDF] U.S. Department of the Treasury ATTN: Office of General Counsel 1500 Pennsylvania Avenue NW Washington, DC 20220 Docket no. TREAS-DO-2025-0037 RIN 1505-ZA10 Re: GENIUS Act Implementation The Conference of State Bank Supervisors (“CSBS”) [1] provides the following comments regarding the U.S. Department of the Treasury (“Treasury”) advance notice of proposed rulemaking (“ANPRM”) on the
November 4, 2025
Press Room

Tokenized Deposit Guidance and Robust Stablecoin Rules Must Be Issued in Tandem

Washington, D.C. – In separate letters to the U.S. Treasury Department and the federal banking agencies, CSBS outlined important policy considerations to foster a national regulatory framework for stablecoins and tokenized deposits that protects consumers, promotes financial stability, and provides a level playing field for traditional financial institutions and new
November 4, 2025
Comment Letter

GENIUS Act Implementation

Download the Full Comment Letter [PDF] U.S. Department of the Treasury Attention: Office of General Counsel 1500 Pennsylvania Avenue NW Washington, DC 20220 RIN 1505-ZA10 Re: GENIUS Act Implementation Dear Sir or Madam: The Conference of State Bank Supervisors (“CSBS”) respectfully requests that the U.S. Department of the Treasury (“Treasury”) extend the comment period an additional 30 days for the
September 24, 2025
Press Room

Broad Coalition to Congress: Strike Uninsured Depository Flaw in Genius Act

Washington, D.C. – A broad coalition of state, consumer, and bank groups have joined the Conference of State Bank Supervisors (CSBS) in asking Congress to strike a provision in the recently passed stablecoin legislation that risks harming consumers, creates an unlevel playing field for certain uninsured banks, and significantly erodes
August 13, 2025
Comment Letter

CSBS Response to Senate Banking Committee RFI on Digital Asset Market Structure

Download the Full Comment Letter [PDF] August 5, 2025 The Honorable Tim Scott Chairman Committee on Banking, Housing & Urban Affairs United States Senate Washington, DC 20510 The Honorable Cynthia Lummis United States Senate Washington, DC 20510 The Honorable Bill Hagerty United States Senate Washington, DC 20510 The Honorable Bernie Moreno United States Senate Washington, DC 20510 Re: Digital Asset
August 5, 2025
Press Room

Stablecoin Framework Must be Sustainable

Washington, D.C. – Conference of State Bank Supervisors (CSBS) President and CEO Brandon Milhorn Statement on House Passage of the GENIUS Act: “A national regulatory framework for stablecoins is a vital precondition for a broader, innovative digital asset ecosystem in the United States. The GENIUS Act is a historic, bipartisan
July 17, 2025
Press Room

CSBS Statement on Passage of Senate Stablecoin Act

Washington, D.C.- CSBS President and CEO Brandon Milhorn Statement on Senate Passage of the GENIUS Act: “A national framework for stablecoins will only be successful if it protects consumers and financial stability. CSBS appreciates the efforts of the Senate to improve the GENIUS Act, moving the bill closer to these
June 17, 2025
Press Room

Keynote Remarks 2025 Fintech Conference

Keynote Remarks 2025 Fintech Conference: Bank-Fintech Partnerships|Distributed Ledger Technology|Regulation and Fintech Innovation Conference of State Bank Supervisors President and CEO Brandon Milhorn Federal Reserve Bank of San Francisco April 4, 2025 Thank you for that kind introduction. I would like to thank President Mary Daly and the San Francisco Fed
April 4, 2025
Press Room

CSBS Expresses Serious Concerns with Stablecoin Bills

State regulators call for changes to support innovation, stability, and predictability Washington, D.C. – The Conference of State Bank Supervisors (CSBS) today raised serious concerns about stablecoin legislation in a letter to House Financial Services Committee leadership. CSBS previously expressed similar concerns about the Senate stablecoin bill. “Without the adoption
April 1, 2025
Comment Letter

Letter to House Committee on STABLE Act

Download the Full Comment Letter [PDF] The Honorable French Hill Chairman Committee on Financial Services U.S. House of Representatives Washington, D.C. 20515 The Honorable Maxine Waters Ranking Member Committee on Financial Services U.S. House of Representatives Washington, D.C. 20515 Dear Chairman Hill and Ranking Member Waters: On behalf of state regulators and the Conference of State Bank Supervisors (CSBS), I
April 1, 2025
Comment Letter

Letter to Senate Committee on GENIUS Act

Download Full Comment Letter [PDF] The Honorable Tim Scott The Honorable Elizabeth Warren Chairman Ranking Member United States Senate United States Senate Washington, D.C. 20510 Washington, D.C. 20510 Dear Chairman Scott and Ranking Member Warren: On behalf of state regulators and the Conference of State Bank Supervisors (CSBS), we write to share our serious concerns with the current draft of
March 13, 2025
Press Room

CSBS Statement on Congressional Stablecoin Progress

Conference of State Bank Supervisors President and CEO Brandon Milhorn Statement on Congressional Progress on Stablecoin Legislation: “State regulators thank Senators Cynthia Lummis and Kirsten Gillibrand for their acknowledgment of the critical role that state bank regulators play in the licensing, regulation, and supervision of money transmission and other nonbank
April 17, 2024
Comment Letter

CSBS Relays Concerns with SEC's Staff Accounting Bulletin 121

Read the Full Letter [PDF] The Honorable Patrick McHenry Chairman House Financial Services Committee Washington, DC 20515 The Honorable Maxine Waters Ranking Member House Financial Services Committee Washington, DC 20515  Chairman McHenry and Ranking Member Waters,  On behalf of the Conference of State Bank Supervisors, 1 I write to relay our concerns with the U.S. Securities and Exchange Commission’s (SEC)
February 28, 2024
Comment Letter

CSBS Comments on Clarity for Payment Stablecoins Act

Download the Full Letter [PDF] The Honorable Patrick McHenry Chairman House Financial Services Committee The Honorable Maxine Waters Ranking Member House Financial Services Committee Chairman McHenry and Ranking Member Waters, On behalf of the Conference of State Bank Supervisors, 1 I am writing to stress the importance of maintaining a robust state regulatory framework for new financial services technologies and
July 25, 2023
Comment Letter

On Cryptocurrencies

The Honorable Pat Toomey Ranking Member Senate Banking Committee Washington, D.C. 20510 Dear Ranking Member Toomey, The Conference of State Bank Supervisors (CSBS) 1 appreciates the opportunity to highlight the critical role of state bank regulators in supervising money transmission and virtual currencies. State regulators charter and supervise 79 percent of all U.S. banks and are the primary regulators of
September 27, 2021

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