Submission to the Office of the Comptroller of the Currency

GENIUS Act NOPR Comment Letter

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.

← All policy submissions