# Supplemental Comment — BNP Framework Expansion

- Regulator: Federal Deposit Insurance Corporation (FDIC)
- Date filed: 2026-03-09
- 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](https://www.federalregister.gov/citation/90-FR-59409)
- Filed submission: https://www.fdic.gov/federal-register-publications/supplemental-comment-auditchain-labs-ag-jason-meyers-rin-3064-ag20
- Web page: https://auditchain.com/about/policy/fdic-supplemental-comment-bnp-framework-expansion-rin-3064-ag20/

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.

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Part of [Auditchain Labs AG: regulatory policy submissions](https://auditchain.com/about/policy/)