- Regulator
- Office of the Comptroller of the Currency (OCC)
- Date filed
- Filed by
- Auditchain Labs AG
- Federal Register citation
- 91 FR 10202
- Docket ID
- OCC-2025-0372
- RIN
- 1557-AF41
- Responding to
- Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency
Summary
Responding to the OCC's NOPR (91 FR 10202, Mar. 2, 2026), this letter proposed a comprehensive BNP disclosure framework to strengthen the operational-risk-management provisions of proposed § 15.13, supplied draft regulatory text for a new § 15.13(c) requiring weekly, monthly, and interim machine-readable XBRL reporting, and offered six targeted amendments to § 15.13(a) and (b) for blockchain-specific controls. It extended the taxonomy to 125 elements and argued that fact-based BNP disclosure is superior to the OCC's proposed rebuttable presumption on staking and yield — invoking the major questions doctrine and Congress's active legislating via the CLARITY Act. Includes five exhibits, among them proposed regulatory text and a cross-reference mapping to the FDIC submission.