The American Fintech Council (AFC), an industry association representing responsible financial technology companies and innovative banks, has formally submitted a comment letter to the Office of the Comptroller of the Currency (OCC).
The letter directly responds to the OCC’s Notice of Proposed Rulemaking to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act, widely known as the GENIUS Act. In its submission, the AFC strongly advocates for a foundational federal framework that bolsters the integrity of the U.S. financial system while preserving the necessary capacity for market participation and technological innovation.
Tailoring rules to issuer risk profiles
A central theme of the AFC’s letter is the necessity of calibrating regulatory expectations to match the size, complexity, and specific risk profile of the issuing entity. The council emphasized that the resulting regulatory framework must remain distinctly risk-based. By avoiding duplicative regulatory requirements, the OCC can prevent policies that might inadvertently inhibit market entry and stifle competition among digital asset innovators.
Phil Goldfeder, chief executive officer of the American Fintech Council, highlighted the historic nature of the legislation and the critical importance of its proper implementation. Goldfeder stated that the GENIUS Act represents a major milestone in operationalizing a framework for payment stablecoins, which will ultimately enhance payment efficiency and reinforce the global competitiveness of U.S. financial infrastructure. He expressed appreciation for the OCC’s thoughtful engagement in establishing a durable regulatory regime, reiterating that the rules must be carefully tailored to the unique operational profiles of individual stablecoin issuers.
Reserves, redemption, and federal clarity
To build a durable and trusted digital asset market, the AFC expressed strong support for a strict reserve and redemption framework grounded entirely in high-quality, highly liquid assets. The association stressed that these underlying assets must be capable of being converted to cash on a timely basis to ensure that redemptions can be consistently fulfilled at par on demand. Furthermore, the council advocated for a clear, unambiguous delineation between federal and state regulatory authorities to reduce market fragmentation and provide necessary operational certainty for all participants.
Ian P. Moloney, chief policy officer at the AFC, noted that 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. Moloney explained that the AFC’s recommendations support a highly practical approach aligned with existing supervisory regimes, allowing regulators to focus on safety, soundness, and consumer protection outcomes while continuing to accommodate rapidly evolving technologies.
Addressing operational logistics, the letter highlighted specific recommendations regarding custody requirements, concentration risk, and reporting obligations. Notably, the AFC suggested that the OCC should permit subsidiaries of insured depository institutions to maintain their stablecoin reserve assets directly within Federal Reserve master accounts or designated subaccounts. According to the council, this structural allowance would significantly promote consistency and safety across the ecosystem while heavily reducing the operational burdens placed on compliant issuers.
