Submission to the Federal Deposit Insurance Corporation

Supplemental Comment — BNP Framework Expansion

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

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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