Banking and Finance Law Daily Wrap Up, FINANCIAL TECHNOLOGY—ABA, BPI ask OCC to delay stablecoin reporting form changes, (Aug 12, 2026)

By Nora Macaluso

Banking groups said the public should have a chance to comment on proposed reporting forms after underlying regulations are finalized.

The American Bankers Association and Bank Policy Institute urged the Office of the Comptroller of the Currency (OCC) to delay its plan to propose new reporting forms for businesses that want to issue stablecoins. The OCC is seeking comment on proposed application forms for businesses seeking approval or registration to issue payment stablecoins under the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act (see Banking and Finance Law Daily, July 24, 2026).

The OCC should propose new forms “only after it has finalized” regulatory requirements for permitted payment stablecoin issuers (PPSIs), and it should work with other regulators to ensure the forms are similar, the groups said. “The public should have the opportunity to comment on proposed reporting forms that align with the underlying substantive regulations,” which are subject to change as the proposed substantive rule is still outstanding, they said.

“The rulemakings to be promulgated under the GENIUS Act represent an interrelated body of regulations of extraordinary scope and complexity, implementing a wholly new statute that is the first federal legislation governing payment stablecoins,” the associations said in a joint letter.

“A fragmented comment process with staggered deadlines across (at least) six interdependent proposals issued by (at least) five different agencies (i) undermines the agencies’ own stated goal of ensuring regulatory consistency across the GENIUS Act implementation framework; (ii) prevents the public from adequately evaluating the proposals individually or holistically; and (iii) raises questions about whether the agencies have adequately coordinated in promulgating these rules, as required by section 4(h)(2), and encouraged by section 13(b), of the GENIUS Act,” they said.

The groups also suggested the OCC require quarterly reporting forms for institutions such as uninsured national trust banks that are already subject to reporting requirements for non-issuer activities. Requiring quarterly PPSI reporting forms in addition to existing requirements “would help distinguish reporting related to GENIUS Act-authorized issuer activities from non-issuer activities, promoting transparency and allowing market participants, regulators, and other stakeholders to consistently compare information across issuers, regardless of charter type or organizational structure,” the letter said.

The OCC should also use a weekly reporting form that does not collect information on the balance of reserve assets that are tokenized, as “distinguishing between reserve assets held in tokenized form would impose unnecessary burden on PPSIs and offer little supervisory benefit,” the groups said. They also asked the agency to clarify proposed requirements for those forms.

Companies: American Bankers Association; Bank Policy Institute

RegulatoryActivity: BankingOperations FinancialIntermediaries FinancialStability FinTech PrudentialRegulation