Letter to OCC supports a tailored, supervisory approach that promotes stability as the GENIUS Act is implemented

Washington, D.C. (May 4, 2026) – The American Fintech Council (AFC), the largest industry association representing both responsible fintech companies and innovative banks, submitted a comment letter to the Office of the Comptroller of the Currency (OCC) in response to its Notice of Proposed Rulemaking to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). In its letter, AFC supports a foundational federal framework that strengthens the integrity of the U.S. financial system while preserving capacity for market participation and innovation.

“The GENIUS Act represents a critical milestone in operationalizing a framework for payment stablecoins that enhances payment efficiency and reinforces the global competitiveness of U.S. financial infrastructure,” said Phil Goldfeder, CEO of the American Fintech Council. “We appreciate OCC’s thoughtful engagement and efforts to establish a durable regulatory regime. It is essential that the resulting framework remains risk-based and tailored to the unique profiles of stablecoin issuers, avoiding duplicative requirements that could inhibit market entry and reduce competition.”

In its letter, AFC highlights several key principles for a durable regulatory framework, emphasizing that regulatory expectations should be calibrated to the size, complexity, and risk profile of the issuer. The letter also expresses support for a reserve and redemption framework grounded in high-quality, highly liquid assets capable of being converted to cash on a timely basis to support redemption at par on demand. AFC also advocates for clear delineation between federal and state regulatory authorities to reduce fragmentation and provide certainty for market participants.

“A durable regulatory framework for payment stablecoins must be grounded in a clear understanding of the underlying risks associated with issuance, redemption, and operational infrastructure,” said Ian P. Moloney, Chief Policy Officer at AFC. “Our recommendations support an approach that is practical and aligned with existing supervisory regimes. By focusing on safety, soundness, and consumer protection outcomes, regulators can create a framework that remains effective while accommodating evolving technologies.”

The letter further highlights recommendations regarding custody requirements, concentration risk, and reporting obligations. AFC suggests that OCC permit subsidiaries of insured depository institutions to maintain reserve assets directly in Federal Reserve master accounts or designated subaccounts, promoting consistency and safety while reducing operational burden.

A standards-based organization, the American Fintech Council (AFC) is the largest and most diverse trade association representing financial technology (fintech) companies and innovative banks. On behalf of over 150 member companies and partners, AFC promotes a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.

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