Submission to the Federal Deposit Insurance Corporation

GENIUS Act Reporting Forms Comment (Forms PS-01, PS-01a and PS-02)

Regulator
Federal Deposit Insurance Corporation (FDIC)
Date filed
Filed by
Auditchain Labs AG
Federal Register citation
91 FR 45274
OMB control number
3064-0225
Responding to
Reporting Forms and Instructions Associated With Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers

Summary

Responding to the FDIC's request for comment on its proposed weekly and quarterly reporting forms for permitted payment stablecoin issuers (91 Fed. Reg. 45274, July 20, 2026), this 79-page submission answers the agency's question on which structured format would work best: XBRL, the standard the FDIC has used for Call Reports since 2005, in one taxonomy shared with the OCC. It makes three points: file the reports in a format the FDIC already runs; publish the checks the instructions already describe as a machine-executable rule set, so the one-to-one reserve requirement and the 40 percent concentration limit are tested at filing and short-form eligibility is computed rather than asserted; and add BNP schedules covering issuer participation, affiliate participation, and aggregated concentration and systemic risk. Live sample models of all three forms accompany the filing.

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