Global policy engagement on digital asset regulation.

Responding to the FDIC's NOPR establishing the ongoing requirements and standards for FDIC-supervised permitted payment stablecoin issuers and insured depository institutions (91 Fed. Reg. 18534, Apr. 10, 2026; to be codified at 12 CFR Parts 324, 330, and 350), this letter carries the BNP framework from the application stage into the operational regime that governs issuers after approval. It makes five recommendations: incorporate machine-readable BNP disclosure into proposed § 350.6 through a new § 350.6(c) plus six targeted amendments; require XBRL filing of all PPSI disclosures; weekly, monthly reserve-composition, and quarterly; coordinated through the FFIEC; refine the yield-prohibition rebuttable presumption to rely on BNP disclosure as a fact-based enforcement mechanism rather than a broad presumption that may capture legitimate arrangements; adopt the framework's structured definitions for "distributed ledger" and "smart contract" in place of static classification; and coordinate with the OCC under the FFIEC so issuers file once, in one taxonomy, across both jurisdictions. The 148-question questionnaire, 125-element taxonomy, and type-extensions specification from the prior submissions apply with equal force to this proceeding.

Updated the BNP disclosure exhibits to add a seventh category covering non-affiliate third-party service provider arrangements, extending the taxonomy from 107 to 125 elements and the disclosure questionnaire from 136 to 148 questions across eight sections. The supplemental introduced the framework's equal-input / equal-output validation architecture — a strict one-to-one correspondence between a range of disclosure questions and a single XBRL concept so that omissions are programmatically detectable. This directly implements the GENIUS Act's anti-evasion mandate under 12 U.S.C. § 5903(h)(1) and supports the FDIC's examination authority under § 5905(a)(3). This is the authoritative current version of the BNP framework, incorporated by reference in our later filings.

Recommended a hybrid application format; a structured, XBRL-tagged form capturing standardized data alongside narrative policies, and proposed Blockchain Network Participation disclosure as core application content under proposed § 303.252(d)(1). The letter introduced the original 107-element BNP taxonomy and a 136-question disclosure questionnaire (Exhibits A–C, including draft sample terms and a type-extensions specification), and recommended that the FDIC add an XBRL structured-data requirement to § 303.252(d)(2), leveraging the FFIEC's proven Call Report XBRL infrastructure to evaluate safety, soundness, and conflicts of interest without duplicative information requests.

Responding to the OCC's NOPR (91 FR 10202, Mar. 2, 2026), this letter proposed a comprehensive BNP disclosure framework to strengthen the operational-risk-management provisions of proposed § 15.13, supplied draft regulatory text for a new § 15.13(c) requiring weekly, monthly, and interim machine-readable XBRL reporting, and offered six targeted amendments to § 15.13(a) and (b) for blockchain-specific controls. It extended the taxonomy to 125 elements and argued that fact-based BNP disclosure is superior to the OCC's proposed rebuttable presumption on staking and yield — invoking the major questions doctrine and Congress's active legislating via the CLARITY Act. Includes five exhibits, among them proposed regulatory text and a cross-reference mapping to the FDIC submission.

Supporting the OCC's clarification of national trust bank chartering authority under 12 U.S.C. § 27(a) and 12 CFR § 5.20, this letter proposed a new memorandum schedule — Schedule RC-T-DA (Digital Asset Custody and Blockchain Network Participation) — as an extension of the existing quarterly Call Report rather than a new information collection. It adapted the FDIC framework into roughly 80 line items with three custody-specific additions (total custodied value, custody account count, and beneficial-owner count) and recommended that coordinated specifications be developed through the FFIEC Task Force on Reports, positioning the OCC to supervise digital asset custody with the rigor applied to traditional custody.

Responding to the NCUA's proposed rule on PPSI investment and licensing, this focused comment made two principal recommendations: that applicants under proposed § 706.105 disclose BNP activities as part of the application's description of related activities, and that the NCUA adopt XBRL-based structured data for application submissions in coordination with the FDIC, OCC, and Federal Reserve. It supported the joint-application structure, urged a cross-agency mutual recognition framework for PPSI licenses to avoid disadvantaging credit unions, and addressed the selective application of Part 712 CUSO requirements. The letter noted that, unlike the banking agencies, the NCUA does not yet operate XBRL reporting infrastructure making this rulemaking its first opportunity to adopt the standard and harmonize with the Financial Data Transparency Act.

Comment on the SEC Staff Statement addressing broker-dealer registration requirements for Covered User Interface Providers in the digital asset markets. The letter situates structured disclosure as the supervisory foundation for any registration framework, arguing that machine-readable reporting allows the Commission to monitor intermediary activity at scale. 

Responding to SEC Chairman Atkins' Statement on Reforming Regulation S-K, this letter argues that the materiality problem is as much about how disclosure is made as what is disclosed. It recommends extending Inline XBRL requirements from Regulation S-X financial statements to key S-K items — Item 101 (Business), Item 105 (Risk Factors), Item 106 (Cybersecurity), Item 303 (MD&A), and Item 601 (Exhibits); adopting BNP disclosure requirements for registrants materially dependent on public networks; and coordinating SEC taxonomy development with the FDIC and OCC frameworks for interagency consistency. It draws four blockchain disclosure categories from the FDIC questionnaire and taxonomy, anticipating the new classes of SEC-registered entities the GENIUS and pending CLARITY Acts will create.

Responding to the PCAOB's 2026–2030 strategic priorities, this letter advances the thesis that audit transformation enables oversight transformation, with machine-readable disclosure as the foundation. It proposes three strategic actions: harmonize with European standards by amending PCAOB AS 4101 to align auditor responsibilities for Inline XBRL / machine-readable filings with the CEAOB's ESEF guidelines, so auditors opine on the machine-readable layer rather than leaving quality issues to post-filing SEC staff review; commit to updating standards to support cryptographically enforced, straight-through audit trails from internal controls to public disclosures; and prepare for the new digital asset audit engagements created by the GENIUS Act — which already mandates PCAOB-registered firm examination of stablecoin reserve disclosures — and the pending CLARITY Act, including on-chain attestations, smart contracts, and tokenized assets.

Auditchain's response to the FCA's Consultation Paper CP26/13, Cryptoasset Perimeter Guidance (April 2026), which sets out proposed guidance on the scope of the new regulated cryptoasset activities taking effect 25 October 2027. The submission answers each of the consultation's six questions and adds architectural observations on how the new perimeter interacts with adjacent UK regimes — the Critical Third Parties regime under section 312L of FSMA, the Bank of England's proposed regime for sterling-denominated systemic stablecoins under Part 5 of the Banking Act 2009, and the HMRC Cryptoasset Reporting Framework under SI 2025/744. It maps each section of the BNP disclosure framework to the UK statutory, regulatory, and perimeter-guidance provisions it engages. The consultation closes 3 June 2026, with final guidance expected in September 2026.