- Regulator
- Office of the Comptroller of the Currency (OCC)
- Date filed
- 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
Summary
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.