# Proposed Reporting Forms Comment (Forms PS-01 and PS-02)

- Regulator: Office of the Comptroller of the Currency (OCC)
- Date filed: 2026-08-14
- Filed by: Auditchain Labs AG
- Federal Register citation: 91 FR 35795
- OMB control number: 1557-NEW
- OCC Bulletin: 2026-24
- Responding to: [Reporting Forms and Instructions for Permitted Payment Stablecoin Issuers Subject to the Jurisdiction of the Office of the Comptroller of the Currency](https://www.federalregister.gov/d/2026-11856)
- Article and analysis: https://auditchain.com/auditchain-labs-responds-to-occ-proposed-disclosure-forms/
- Web page: https://auditchain.com/about/policy/occ-proposed-reporting-forms-comment-ps-01-ps-02/

Responding to the OCC's request for comment on proposed Forms PS-01 (weekly) and PS-02 (quarterly) for OCC-supervised payment stablecoin issuers (91 FR 35795, June 12, 2026), this letter moves from argument to working proof. Both forms are expressed as machine-readable XBRL report models that open in a browser, carrying every schedule the OCC proposed plus three BNP schedules (I, J and K on PS-01; F, G and H on PS-02) and machine-testable validation rules. It makes seven recommendations: adopt the BNP schedules; specify XBRL as the filing format; deliver an executable rule set with the forms; test one-to-one backing inside the collection itself; require the basis and source for estimated figures; harmonize with the FDIC's parallel collection; and identify each institution and affiliate by Legal Entity Identifier. An exhibit carries proposed statutory text for BNP disclosure addressed to Congress.

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