Circle Urges OCC to Finalize Strong GENIUS Act Stablecoin Rules

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Key Takeaways

Circle Backs National Stablecoin Licensing Standards

Circle Internet Group (NYSE: CRCL) revealed May 5 that it had submitted comments on May 1 to the Office of the Comptroller of the Currency (OCC) regarding the regulator’s proposed GENIUS Act rule. The filing supports a national licensing regime for payment stablecoins and clearer oversight standards for dollar-backed digital payment instruments.

The OCC proposal sets standards for reserves, redemption, information security, supervision, compliance, and operational readiness. Circle said those requirements should reflect the demands placed on major payment stablecoin issuers. The company emphasized reliable redemption, operational resilience, and continuous 24/7/365 functionality. It also said regulated payment stablecoins should remain transferable, fungible, and usable across customers, platforms, and markets. Circle wrote:

“The OCC’s rulemaking turns the GENIUS Act into a durable framework that works in practice, requiring issuers to meet highest-level standards of a standalone, ring-fenced entity with all of the capacity to meet the large demands placed on global issuers.”

The filing also argued that issuers should compete under common prudential rules. That includes bank, nonbank, state, federal, domestic, and foreign issuers. Circle said uneven standards could weaken trust, create arbitrage, and disadvantage compliant firms. The point is that stablecoin oversight should not depend on issuer type or charter path.

OCC Proposal Sets Broader Stablecoin Oversight Path

The OCC’s proposal would apply to national banks, federal savings associations, federal branches, foreign issuers, and certain state-qualified payment stablecoin issuers under its jurisdiction. Most requirements would sit in a new 12 CFR 15, covering reserves, redemption, risk management, supervision, custody, applications, and operational backstops. The OCC also said anti-money laundering and sanctions-related rules would be addressed separately with the Treasury Department.

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Circle said the final framework should support global standards for trusted digital dollars while preserving transferability and reliable redemption. The company also called for oversight covering credit, liquidity, operational, and anti-money laundering risks. Circle stated:

“With clear, practical, and consistently applied rules, the United States can protect consumers, build the market of the future, and strengthen the role of trusted digital dollars in the global economy.”



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