Banking and Finance Law Daily Wrap Up, FINANCIAL TECHNOLOGY—Banking groups seek extension of comment period for GENIUS Act, (Sep 24, 2025)
Organizations Mentioned:American Bankers Association | America’s Credit Unions | Bank Policy Institute | Community Development Bankers Association | Consumer Bankers Association | Independent Community Bankers Association | The Clearinghouse Association
By Nora Macaluso
The groups said a 60-day extension would allow for more comprehensive responses.
Banking trade groups asked the Treasury Department to extend the comment period for its advance notice of proposed rulemaking (ANPRM) for implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The Treasury issued the notice Sept. 19 and asked for comments by October 20 (see Banking and Finance Law Daily, Sept. 18, 2025).
The notice “poses nearly 60 foundational questions across a wide range of complex and interrelated topics,” the groups—the American Bankers Association, America’s Credit Unions, Bank Policy Institute, Community Development Bankers Association, Consumer Bankers Association, Independent Community Bankers Association, and The Clearinghouse Association — wrote in a letter to Tian Huang and Shane Shannon, counselors to the General Counsel at the Treasury.
“Given the breadth and depth of the issues raised—and the importance of providing Treasury with thoughtful, data-informed, and actionable feedback—we believe that a 30-day comment period is insufficient, the groups said. “A longer comment period would allow stakeholders to engage with member institutions and experts to gather meaningful input.”
The groups asked for an additional 60 days to comment. “This extension would ensure that Treasury receives comprehensive and well-considered responses that support the development of a robust and effective regulatory framework under the GENIUS act,” they wrote.
The GENIUS Act, enacted on July 18, provides a framework for the federal regulation of payment stablecoins. It also asks federal agencies to fill out that outline by providing an appropriately tailored regime to protect consumers, mitigate potential illicit finance risks, and address financial stability risks.
Under the Act, only permitted payment stablecoin issuers (PPSIs) may issue a payment stablecoin in the U.S., subject to certain exceptions. In addition, beginning July 18, 2028, digital asset service providers may not offer or sell a payment stablecoin to anyone in the U.S. unless the payment stablecoin is issued by a PPSI or issued by a foreign payment stablecoin issuer (FPSI) that meets certain requirements.
The GENIUS Act provides three primary categories of PPSIs, all of which must be formed in the U.S.: a subsidiary of an insured depository institution, a federal qualified payment stablecoin issuer, or a state qualified stablecoin issuer.
The Treasury is charged with issuing regulations implementing the requirement that PPSIs are “subject to all Federal laws applicable to a U.S. financial institution located in the United States relating to economic sanctions, prevention of money laundering, customer identification and due diligence.”
It’s also the Treasury’s responsibility to determine whether a foreign country’s regulatory and supervisory regime is comparable to the U.S. framework established by the GENIUS Act, which would allow certain FPSI-issued stablecoins to be offered or sold in the U.S.
The Treasury is seeking comment on issues related to regulatory clarity, prohibitions on certain issuances and marketing, Bank Secrecy Act (BSA) anti-money laundering (AML) and sanctions obligations, the balance of state-level oversight with federal oversight, comparable foreign regulatory and supervisory regimes, and tax issues. It also asked commenters to identify other issues it should consider, especially areas where
Treasury regulations may overlap with or directly implicate the regulations assigned to other state or federal agencies.
Companies: American Bankers Association; America’s Credit Unions; Bank Policy Institute; Community Development Bankers Association; Consumer Bankers Association; Independent Community Bankers Association; The Clearinghouse Association
RegulatoryActivity: BankingOperations BankSecrecyAct Blockchain CapitalBaselAccords DepositInsurance FederalReserveSystem FinancialIntermediaries FinTech Preemption Privacy PrudentialRegulation SecuritiesDerivatives StateBankingLaws