Submission to the Federal Deposit Insurance Corporation

GENIUS Act Requirements & Standards Comment Letter

Regulator
Federal Deposit Insurance Corporation (FDIC)
Date filed
Filed by
Auditchain Labs AG
Federal Register citation
91 FR 18534
RIN
3064-AG19
Responding to
GENIUS Act Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers and Insured Depository Institutions

Summary

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.

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