NCRC Comment to OCC re GENIUS Act NPRM

May 1, 2026

Jonathan V. Gould
Comptroller of the Currency
Office of the Comptroller of the Currency
400 7th Street SW
Washington, DC 20219

Via: Federal eRulemaking Portal — Regulations.gov

Re: Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency [Docket ID OCC-2025-0372]

Dear Comptroller Gould:

The National Community Reinvestment Coalition (NCRC) appreciates the opportunity to comment on the notice of proposed rulemaking (NPRM) issued by the Office of the Comptroller of Currency (OCC) regarding implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).[1]

NCRC is a network of more than 700 community-based organizations dedicated to creating a nation that not only promises but delivers opportunities for all Americans to build wealth and attain a high quality of life. We work with community leaders and policymakers to advance solutions and build the will to solve America’s persistent racial and socio-economic wealth, income, and opportunity divides, and to make a Just Economy a national priority and a local reality. 

As a threshold matter, given the current uncertainties regarding the cryptocurrency and stablecoin market structure, NCRC believes it is premature to finalize this rule. Many issues remain in flux and unresolved and the OCC should not finalize the rule until subsequent legislation addresses those issues. Despite this uncertainty, NCRC requests that the OCC address the following pressing concerns raised by the OCC GENIUS Act NPRM:

• The potential for increased deposit flight risks related to the yield provisions and the reserve requirements;
• The potential for bank runs and systemic risk to the banking system;
• A lack of clarity regarding redemption and disclosure regimes given the role of exchanges and third party intermediaries; and
• The need for a charge-back type system that imposes obligations on issuers to investigate assertions by stablecoin customers of fraud and fraudulent inducement and make them whole.

1. The evolving legislative and regulatory environment is too uncertain to finalize this rule; the OCC should allow more time for commenting.

The regulatory and legislative framework for stablecoins and digital assets remains in flux. As the OCC notes, its GENIUS Act NPRM is just “one piece of the GENIUS Act’s implementing regulations.”[2] Several other agencies have issued or are issuing NPRMs to implement other portions of the GENIUS Act, including the Department of Treasury (Treasury) and the Federal Deposit Insurance Corporation.[3] Notably, the NPRM issued by Treasury proposes that when evaluating the regulatory framework of a state to determine whether it is substantially similar to the Federal regulatory framework, the “OCC’s interpretations and regulations  . . . should be the baseline for comparison[.]”[4] In addition, while this rulemaking is pending, Congress is determining how to further legislate the digital asset market – the House has passed the Clarity Act (HR 3633) bill, the Senate Agricultural Committee has voted out of Committee the Digital Commodity Intermediaries Act (S. 3755) bill, and the Senate Banking Committee is considering the Responsible Financial Innovation Act bill. Some areas covered by these bills overlap with this NPRM. Considering the fluid nature of the regulatory and legislative environment, the OCC should extend the comment period for the GENIUS Act NPRM to allow commenters the opportunity to comment on and the OCC to regulate a more static situation armed with more concrete information.

2. Yield provisions and presumption do not go far enough to prevent deposit flight.[5]

Payment of yield on stablecoin balances is a prime example of an unresolved issue. The GENIUS Act prohibits permitted payment stable coin issuers[6] from paying “the holder of any payment stable coin any form of interest or yield (whether in cash, tokens, or other consideration) solely in connection with the holding, use, or retention of such payment stablecoin.”[7] The prohibition in the statute is limited to issuers, not other players in the stablecoin ecosystem, namely, cryptocurrency exchanges through which issuers currently indirectly pay yield to holders. For example, exchanges can hold stablecoin on the blockchain on behalf of a retail holder. Some issuers pass interest earned on the reserves it holds to the exchange, which the exchange then uses to pay the retail holder yield.[8] Exchanges may also pay yield to holders through other means, as well.

The OCC GENIUS Act NPRM does not sufficiently address the issue of indirect payment of yield. It proposes to establish a rebuttable presumption that payment of interest or yield occurs if the issuer has an arrangement to pay interest or yield to a holder “solely in connection with the holding, use, or retention” of its stablecoin. The presumption covers affiliates and related third parties of the issuer but defines those terms narrowly.[9] A related third party, for example, includes any person paying interest or yield as a service to the issuer.[10] For the presumption to apply, there must be (1) an agreement between issuer and the related third party or affiliate for the issuer to pay the third party/affiliate yield or interest and (2) an agreement between the third party/affiliate to pay holders of the issuer’s stablecoin interest or yield.[11] While the definitions are broader than those in the GENIUS Act, they do not go far enough to prevent the payment of yield to stablecoin holders. Yield that indirectly flows to holders through exchanges and third party intermediaries is not addressed and thus creates a loophole that issuers can exploit.[12] If issuers provide interest or other payments to an exchange but do not otherwise formally contract with the exchange to provide the yield to its stablecoin holders, the issuer will avoid coverage of the prohibition.

The OCC NPRM should define “holder” – it currently does not,[13] nor does the GENIUS Act – to include individuals and entities that possess stablecoins, including exchanges and other similar companies.[14] Doing so would clarify that issuers should not pay yield to any type of holder of its stablecoins, including exchanges. If exchanges do not receive yield or payments from issuers, then exchanges would have less ability to pass it along to holders. Taking this step would reduce the potential for deposit flight.

Congress is currently debating this issue of yield payments to stablecoin holders because allowing such yield payments –from issuers or third parties– will likely result in “deposit flight,” namely the movement of funds by households and business from bank deposit accounts to stablecoins. Bank deposits fund bank lending activities and community investment and development. The incentivizing of stablecoins and the resulting deposit flight thus will seriously impair banks’ lending capabilities and ability to invest in their communities. According to the American Bankers Association, this is especially true of smaller community banks.[15] It notes that when community banks lose deposits, they must replace the funding, “often through higher-cost wholesale borrowing” and “the increased funding costs translate into less lending and higher borrowing costs for households and small businesses.”[16]

Banks operate within a broader public policy framework designed to ensure that federally supported financial institutions help meet household, small business, and community credit needs. Stablecoin issuers may increasingly compete with banks for customer funds while operating under a very different regulatory framework. OCC should consider whether large-scale migration of funds into stablecoin ecosystems could weaken the flow of capital into communities that depend on traditional lending institutions.

A recent report indicated that stablecoins could divert around $500 billion of potential deposits from US banks by the end of 2028.[17] As a result, communities will lose billions of dollars of needed community and economic development projects and initiatives. In 2023 alone, banks originated over $126 billion in loans that meet the Community Reinvestment Act[18] (CRA) definition of community development for low- to moderate income communities and households.[19]

NCRC has long advocated for requiring stablecoin issuers to reinvest a portion of their proceeds into community development projects in underserved communities.[20] It would allow for a more level playing field between banks and stablecoin issuers (including national trust bank holders). Regulators regularly supervise traditional banks for their compliance with the CRA. If subject to similar requirements, regulators could also hold stablecoin firms accountable for meeting their community investment obligations. Given that no market structure legislation is final, there is still time for Congress to impose such a requirement. For example, stablecoin issuers could direct a portion of the interest they accrue on reserve deposits to community reinvestment, rather than flowing the interest back to issuers or to exchanges or other stablecoin holders.

The GENIUS Act’s narrow prohibition on the payment of stablecoin yield raises significant deposit flight concerns that the OCC GENIUS Act NPRM’s clarifications about affiliates and related third parties do not address. The rebuttable presumption does not go far enough to address indirect payment of yield by stablecoin issuers through exchanges. Including exchanges and similar third parties in the definition of holder would be an important step in the right direction. However, the OCC should not finalize its regulatory regime until Congress resolves the yield issue in market structure legislation.

3. Reserve Requirements Raise Deposit Flight and other Risks.[21]

The GENIUS Act requires issuers to keep assets in reserves that are roughly equal to the outstanding value of its stablecoin in circulation.[22] The premise is that these assets must be easily liquidated to meet holder redemption requests. The OCC GENIUS Act NPRM sets out what types of assets are eligible to be reserves, as well as diversification and deposit concentration requirements.[23] The OCC GENIUS Act NPRM allows a variety of types of assets to act as reserves, including cash deposits,[24] Treasury bills (with a maturity date of less than 93 days)[25] and tokenized assets.[26]

The NPRM sets out two options regarding the diversification of requirements – the first allows flexibility using what it calls a principles-based approach[27] with a safe harbor (Option A) and the second sets forth mandatory requirements (Option B).[28] The mandatory and safe harbor requirements are identical. For example, under both the safe harbor and the mandatory requirements at least 10% of the reserves must be held as deposits at an insured depository institution, credit union or Federal Reserve Bank, with no more than half of those assets at a single institution.[29] NCRC prefers mandatory requirements to less measurable standards but cautions that inclusion and overconcentration of these asset types may further contribute to deposit flight.

With respect to cash deposits, we are concerned that the reserve requirements will encourage the channeling of deposits away from community and smaller banks to larger “too big to fail” banks or custodial banks as reserves.[30] And that this will create another path for the deposit flight from community and smaller banks and their losing deposits that fund their community investments and lending.

If reserve accounts include an over-concentration of Treasury bills, large sums of money will move outside the banking system entirely, not just deposits.[31] But those sums will be federally guaranteed by the full faith and credit of the US government for the value at maturity.[32] In contrast, FDIC-insured deposits are insured up to $250,000. This difference may create the impression that stablecoins are safer than deposit accounts and further encourage deposit flight.

The inclusion of tokenized assets, although generally authorized by GENIUS Act,[33] as an eligible asset type also raises concerns. If the goal of having stable reserves is to ensure the easy redemption of stablecoins, it is not clear how having tokenized assets in reserves will advance that goal. Blockchain technologies are often subject to exploitation and there is no guarantee of protection of tokenized reserve assets from such exploitation. Their value is often volatile and if there is underlying market stress in the digital market, it may impact the value and liquidity of the tokenized assets. Allowing tokenized assets adds uncertainty and instability to the reserves.

The role of custodians of reserves is also concerning. First, the NPRM allows issuers to hold their own reserve assets.[34] NPRM Question 47 asks whether the OCC should expressly require that a certain percentage of reserve assets be held in the custody of an affiliate or a third party.[35] NCRC strongly believes that the majority of an issuer’s reserve assets should be held by unaffiliated third parties, as opposed to the issuer or its affiliates, including when the issuer holds a national trust bank charter. If the issuer is experiencing financial stress, it is likely to spread to its entire business, including its affiliates. Even if the reserves are appropriately segregated, issuers and affiliates may have operational limitations caused by their financial stress. NPRM Question 172 asks whether the OCC should only allow permitted issuers to issue a single type or brand of stablecoin to ensure the legal separateness of reserve assets backing a stablecoin issuer’s stablecoin.[36] NCRC agrees that limiting stablecoin issuers to a single type or brand of stablecoin will help ensure legal separateness – and adequacy – of reserves.[37]  

Second, the OCC NPRM affirmatively allows a practice by custodians that has been problematic in other contexts – the use of omnibus accounts by reserve custodians.[38] In addition to this provision being at odds with other provisions that attempt to ensure segregation of accounts, the recent example of the bankruptcy of Synapse Financial Technologies, demonstrates the challenges of such arrangements. Synapse was a “banking as a service” business providing online banking services to consumers through its partnerships with FDIC-regulated banks. The banks held the consumers’ funds commingled or omnibus accounts.[39] When Synapse went bankrupt, its records or ledger mapping individual consumer’s account funds to the commingled bank accounts were inadequate and over 100,000 consumers lost access to their funds. No one could identify who owned which assets.[40] The Consumer Financial Protection Bureau sued and settled with Synapse in the bankruptcy proceeding, allowing it to use its Civil Money Penalty Fund to provide relief to injured consumers.[41]

The Synapse collapse is a cautionary tale that supports not allowing omnibus accounts in the context of stablecoin reserves– the issue for Synapse resulted from minor discrepancies based on timing differences between bank settlement and ledger updates that were compounded based on the scale of the transactions.[42] Absent government action, thousands of consumers would have not been made whole. With stablecoins, the volatility of digital assets and their impact on the financial market may exacerbate the differences between reserves and ledgers. The commingling of assets in omnibus accounts puts redemption by holders at risk. Even though the GENIUS Act grants stablecoin holders “super priority” interest in reserves in the event of bankruptcy, because the reserves are not part of the bankruptcy estate, the bankruptcy trustee cannot use reserves to pay for administrative expenses related to the bankruptcy.[43] So, if there are inadequate assets in the bankruptcy estate to pay for the administrative costs associated with parsing commingled reserves, holders may be out of luck. There may not be sufficient funds available to establish what portion of the reserves are owed to whom. This dynamic increases the likelihood that government intervention will be necessary in the case of bankruptcy involving custodians with omnibus reserve accounts. Accordingly, the OCC should not allow custodians to hold omnibus reserve accounts.[44]

4. Redemption and the Risk of Bank Runs[45]

The OCC NPRM requires timely redemption of stablecoins, generally within two days of a valid request.[46] However, it also provides for extensions of the time frame, for example to 7 days where holders seek in excess of 10% of the outstanding value of an issuer’s stablecoin within 24 hours.[47] When there is market volatility or bank stress, the faulty perception that stablecoin reserves mean holders can redeem their funds at any time may cause consumers to think stablecoins are safer than deposits and result in further deposit flight.. Alternatively, if there is instability or uncertainty in the stablecoin market, large numbers of holders may seek redemption from issuers in a short period of time. As a result, issuers may quickly withdraw large deposit balances from banks outside regular banking hours and overwhelm the banks’ capacity and liquidity. This could cause banks to have to quickly liquidate assets, possibly causing systemic stress.

Given the potential risks to safety and soundness and financial stability, the OCC should imposed variable redemption timeframes depending on circumstances but also require notifications and involvement of the OCC as set forth in proposed 15.12(c).[48]

5. Lack of direct relationship between issuers and holders poses challenges for effectiveness of redemption and disclosure requirements.[49]

As discussed above, many holders of stablecoin obtain them through exchanges and other intermediaries. As a result, there is no direct relationship between issuers and many holders. This renders the mandatory initial and redemption disclosure regime outlined in the OCC NPRM ineffective. For example, it requires certain information be disclosed in customer agreements, such as: (i) the name of the issuer; (ii) that the issuer is obligated to convert, redeem, or repurchase the payment stablecoin for a fixed amount of monetary value; (ii) information about the composition of reserves; (iv) all fees associated with purchasing and redeeming stablecoins.[50] It also requires issuers to disclose this information on the issuer’s website and provide updates to customers. There is no obligation for exchanges or other third parties that sell the issuer’s stablecoin to make these disclosures to customers nor that the third parties direct customers to the issuer’s website. Moreover, it remains unclear how the OCC will confirm that the appropriate disclosures are made to the universe of holders of an issuer’s stablecoin.

Similarly, given this lack of direct connection between issuers and holders who purchase stablecoins through third parties or exchanges, it is not clear how such holders will receive the required disclosures regarding redemption rights.[51] The OCC GENIUS Act NPRM requires public disclosure but does not define how the issuer is to publicly disclose this information to holders who purchase through exchanges. Some issuers only “issue” stablecoin to a subset of customers and contractually limit redemption rights to that subset of consumers.[52] This practice raises the question of whether, if the OCC implements the NPRM, issuers can continue to limit their redemption and reserve responsibilities through contract.

Question 106 highlights this tension by asking “[t]o whom should issuers have the responsibility to deliver disclosures regarding changes in fees?” It then asks whether it should include all “all payment stablecoin holders (e.g., retail holders who purchased from an exchange or secondary market) or should it be a narrower subset of holders (e.g., only holders who purchased directly from the payment stablecoin issuer)?”[53] We strongly encourage the OCC to require that the issuer to be responsible for ensuring all stablecoin holders receive all of the appropriate disclosures, regardless of how the holder obtained the stablecoin.

6.  OCC should address fraud concerns by establishing a framework that provides for restitution for victims of stablecoin fraud.[54]

Stablecoins are promoted as a payment mechanism, however currently, there is no way to reverse a blockchain transaction.[55] While legitimate merchants may applaud the lack of chargebacks and the related reduction in their costs, the lack of a mechanism for users to reverse a stablecoin transaction creates an enormous consumer protection issue that scammers exploit and stablecoin issuers potentially benefit from.

Recent reports indicate that stablecoins accounted for the majority of “illicit crypto” transactions in 2024 and 2025 resulting in billions of dollars tied to fraud, scams, and sanctions.[56] One big issue is fraudulently induced stablecoin transactions related to romance, investment, and other frauds and scams (“fraudulent inducement”).[57] For example, fraudulent inducement can occur when a when a consumer sends payment because of an imposter scam, fake investment platform, fake merchant, romance scam, or a fraudulent token is presented as authentic. Although many issuers and exchanges can freeze suspicious transactions, according to recent reports, they do not do so regularly and in some cases do not return the funds to the victims and instead continue to collect interest on the underlying assets.[58]

The OCC should address these fraud concerns in the context of this rulemaking.[59] One option is to adopt protections similar to the unauthorized credit card transaction provisions in Regulation Z which implements the Truth in Lending Act.[60] Once a customer raises an issue regarding an unauthorized transfer – be it a counterfeit token transfer, wallet compromise, private-key theft, malware attack, spoofed address transfer, etc. – or a fraudulently induced transfer, the customer’s liability should be capped. Under Regulation Z, that cap is $50.[61] And, like with Regulation Z, the issuer should be under a duty to investigate the claim, with the burden on the issuer and any other parties that acted as intermediaries to establish the customer authorized the transaction and it was not fraudulently induced. If unable to establish that, the issuer must reimburse the customer up to the cap. Doing so may incentivize issuers to develop technologies that can assist in reversing transactions.

In particular, the OCC should create protections to address fraudulent inducement, so the loss presumptively sits with the stablecoin firm ecosystem unless the firm proves it deployed effective fraud controls such as transaction specific warnings that require consumer acknowledgment. Including protections similar to chargebacks and card-network dispute rights for victims of fraudulent inducement of stablecoin transactions would level the playing field between payment systems.

Without a liability framework for payment stablecoins that is on par with other federal financial consumer fraud protections, stablecoin firms will enjoy a profound and unearned competitive advantage over traditional credit and debit card issuers — who must absorb fraud losses under Regulation Z (and the Electronic Fund Transfer Act and Regulation E)[62] — creating a powerful race to the bottom that redirects consumers toward less-protected payment instruments and undermines long-established  consumer safeguards. The OCC must ensure that fraud-loss allocation rules apply equally across functionally equivalent payment products; allowing stablecoin issuers to offload fraud risk onto consumers while card issuers cannot amounts to a regulatory subsidy that distorts competition and leaves consumers exposed.

Conclusion

The hundreds of questions posed in the GENIUS Act NPRM demonstrate the complexity of the issues associated with stablecoins. Without comprehensive additional legislation to address the significant risk of deposit flight, impact on community investment and lending, and massive consumer fraud losses with no liability backstop, it is premature for the OCC to finalize its proposed rule. We urge the OCC to wait to finalize the rule until the regulatory landscape is clearer. Moreover, when finalizing the Rule, we request that the OCC fully address the potential for deposit flight, bank runs and the systemic risks to the banking system, the role of exchanges and third parties as they relate to disclosures and redemption requests, and fraudulent activities directed to stablecoin customers.

Thank you for the opportunity to offer our input on the OCC GENIUS Act NPRM. If you have any questions, please contact me at jvantol@ncrc.org, or Tara Flynn at tflynn@ncrc.org.

Thank you for your consideration.

Sincerely, 
Jesse Van Tol  
NCRC President and CEO   

[1] Office of the Comptroller of Currency, Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency Notice of Proposed Rulemaking (Feb. 25, 2026) [hereinafter OCC GENIUS Act NPRM].

[2]  OCC GENIUS Act NPRM 91 Fed. Reg. 10202, 10203 (Mar. 2, 2026).

[3] Several trade associations have requested that the agencies proposing these rulemakings extend the deadlines for public comments for 60 days after the issuance of the final rule by the OCC because they are dependent on the OCC’s Genuis Act NPRM. See Letter from Am. Bankers Ass’n, Bank Pol’y Inst., Consumer Bankers Ass’n & Indep. Cmty. Bankers of Am. to Various Agencies (Apr. 21, 2026).

[4] Department of Treasury Notice of Proposed Rulemaking at 8 (April 3, 2026) (hereinafter Treasury NPRM].

[5] See OCC GENIUS Act NPRM Questions 22;35-39.

[6] OCC GENIUS Act NPRM § 15.30 sets out the approval process for stablecoin issuers. Section 13.30(b)(3) contains circular definitions of when an application is substantially complete (e.g., it “is considered substantially complete as of the date the OCC receives the information required for the application to be substantially complete.”). It is unclear whether the OCC must affirmatively determine the application is substantially complete before the NPMR treats it as such. This is concerning because the NPRM provides that a “substantially complete application is deemed approved by the OCC as of the 120^th day after the substantially complete application is received,” unless denied by the OCC. We urge the OCC to not allow for automatic approval of issuer applications in the absence of an affirmative decision by the OCC of not only the completeness of the application but also its sufficiency to meet the regulatory standards.

[7] GENIUS Act § 4(a)(11).

[8] Cong. Rsch. Serv., The Stablecoin Yield Debate (Mar. 2026), https://www.congress.gov/crs-product/IF13174.

[9] OPM GENIUS Act NPRM § 15.10(c)(4).

[10] OCC GENIUS Act NPRM § 15.10 (c)(4)(ii).

[11] OCC GENIUS Act NPRM § 15.10(c)(4)(i).

[12] See OCC GENIUS Act NPRM Questions 35-39.

[13] OCC GENIUS Act NPRM Question 22.

[14] See Cong. Rsch. Serv., The Stablecoin Yield Debate (Mar. 2026), https://www.congress.gov/crs-product/IF13174.

[15] Sayee Srinivasan and Yikai Wang, The CEA Studied the Wrong Question on Stablecoin ‘Yield’ and Community Banks, ABA Banking J. (Apr. 13, 2026), https://bankingjournal.aba.com.

[16] Id.

[17] Hannah Long, U.S. Banks May Lose $500 Billion to Stablecoins by 2028, Standard Chartered Warns, Reuters (Jan. 27, 2026), https://www.reuters.com.

[18] 12 U.S.C § 2901 et seq.

[19] Fed. Fin. Inst. Exam Council, Findings from 2023 Data Fact Sheet (Nov. 12, 2025), https://www.ffiec.gov/data/cra/findings-from-2023-data-fact-sheet.

[20] See Bakari Levy and Kevin Hill, The Need for Community Development Accountability for Stablecoin Issuers, NCRC (Jul. 14, 2025), https://ncrc.org.

[21] See generally OCC GENIUS Act NPRM Questions 44-99; 149-176; 201.

[22] 12 U.S.C. § 5903(a)(1).

[23] OCC GENIUS Act NPRM § 15.11.

[24] OCC GENIUS Act NPRM § 15.11(b)(2).

[25]  OCC GENIUS Act NPRM § 15.11(b)(3).

[26]  OCC GENIUS Act NPRM § 15.11(b)(8).

[27] OCC GENIUS Act NPRM Question 57.

[28]  OCC GENIUS Act NPRM § 15.11(c) Options A and B.

[29]  OCC GENIUS Act NPRM § 15.11(c) (2)(i) Option A; (c)(2)(i) Option B.

[30] ABA Banking Journal, CEA Studied the Wrong Question on Stablecoin “Yield” and Community Banks (Apr. 13, 2026), https://bankingjournal.aba.com.

[31] BH, How T-Bill Issuance Forces Fed Money Printing and Impacts Crypto, CoinPaprika (Nov. 25, 2025), https://coinpaprika.com.

[32] Are Treasury Bills Insured? FDIC vs. Government Backing, LegalClarity (Apr. 1, 2026), https://legalclarity.org.

[33] 12 U.S.C. § 5903(a)(1)(A)(viii).

[34] OCC GENIUS Act NPRM § 15.20, definition of covered custodian.

[35] OCC GENIUS Act NPRM Question 47.

[36] OCC GENIUS Act NRPM Question 172.

[37] NCRC also agrees that paying fees from reserve assets would be inconsistent with requirement for issuers to maintain identifiable reserve assets backing outstanding issuance value, see OCC GENIUS Act NPRM Question 99, and thus the rule should prohibit the charging of general corporate expenses against reserve assets.

[38] OCC GENIUS Act NPRM § 15.22; Question 158.

[39] ABA Banking Journal, FINRA Files Enforcement Action Against Former Synapse Officers over Alleged Supervisory Failures (Oct. 1, 2025), https://bankingjournal.aba.com.

[40] Jelle Van Schaick, The Hidden Cost of Pooled Accounts for Platforms, FinExtra (Feb. 8, 2026), https://www.finextra.com.

[41] Consumer Fin. Prot. Bureau, Enforcement Actions: Synapse Financial Technologies, https://www.consumerfinance.gov/enforcement/actions/synapse-financial-technologies-inc/.

[42] Jelle Van Schaick, The Hidden Cost of Pooled Accounts for Platforms, FinExtra (Feb. 8, 2026), https://www.finextra.com.

[43]12 U.S.C. § 5910; See also Morgan, Lewis & Bockius LLP, The Proposed GENIUS Act Raises Concerns over Insolvency Provisions (July 2, 2025).

[44] OCC GENIUS Act NPRM Question 207 (Should the OCC adopt any new rules or change any existing rules to implement the insolvency provisions of the GENIUS Act?).

[45] See generally OCC GENIUS Act NPRM Questions 100-108; 201.

[46] OCC GENIUS Act NPRM § 15.12(b)(1)(i); Question 100 (How should any definition of “timely appropriately balance consideration of price stability and run risk?”).

[47] OCC GENIUS Act NPRM § 15.12(c).

[48] See OCC GENIUS Act NPRM Question 102 (Should the OCC consider a longer redemption period timely in times of stress?).

[49] See generally OCC GENIUS Act NPRM Questions 105-108.

[50] OCC GENIUS Act NPRM § 15.12(d)(4). With respect to redemption fees, we would encourage the OCC to impose limits on such fees so that they must be reasonable, subject to a regulatory cap, and not modified unilaterally by issuers. See OCC GENIUS Act NPRM Question 104.

[51] OCC GENIUS Act NPRM § 15.12(a).

[52] Christopher K. Odinet, Andrea Tosato & Yesha Yadav, The Moneyness of Stablecoins, Yale L.J. (forthcoming 2026) at 36.

[53] OCC GENIUS Act NPRM Question 106.

[54] OCC GENIUS Act NPRM Question 210.

[55] Plasma, Do Stablecoin Payments Have Chargebacks (Nov. 16, 2025), https://www.plasma.to/learn/stablecoin-chargebacks.

[56] Olivier Acuna, International Finance Watchdog Warns Stablecoins are Increasingly Used in Sanctions Evasion and Money laundering, Coindesk (Mar. 3, 2026), https://www.coindesk.com.

[57] Julia Voo, Stablecoin Rails and the Limits of Financial Power, Int’l Inst. for Strategic Stud. (Mar. 5, 2026), https://www.iiss.org.

[58] Allison Morrow, Stablecoin Law Allows Crypto Firms to Profit from Fraud, Prosecutors Say, CNN (Feb. 2, 2026), https://www.cnn.com.

[59] OCC GENIUS Act NPRM Question 210 asks: “Should the OCC include consumer protection-related compliance risk management principles-based requirements and standards in § 15.13? And if so, are there specific standards the OCC should institute?”

[60] 12 U.S.C. § 1026.12(b).

[61] 12 U.S.C. § 1026.12(b)(ii).

[62] 15 U.S. C. § 1693 et seq.; 12 C.F.R. Part 1005.