Submission to the Federal Deposit Insurance Corporation

Original Comment Letter — Application Requirements

Regulator
Federal Deposit Insurance Corporation (FDIC)
Date filed
Filed by
Auditchain Labs AG
RIN
3064-AG20
Responding to
Approval Requirements for Issuance of Payment Stablecoins by Subsidiaries of FDIC-Supervised Insured Depository Institutions

Summary

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.

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