Washington DC – August 11, 2026 – Auditchain Labs AG, a provider of AI regulatory disclosure automation infrastructure today submitted a formal comment letter to the Office of the Comptroller of the Currency in response to OCC Bulletin 2026-24 and the related Federal Register notice (91 FR 35795) requesting comment on proposed Forms PS-01 (Weekly Payment Stablecoin Activity and Reserve Reporting) and PS-02 (Quarterly Reports of Condition and Income for Permitted Payment Stablecoin Issuers).
The comment urges the OCC to require disclosure of Blockchain Network Participation (“BNP”) activities—mining, validation, staking, and related network operations—by each Permitted Payment Stablecoin Issuer and its affiliates. Auditchain argues that these activities constitute material information affecting safety and soundness, settlement integrity, conflicts already restricted under the GENIUS Act, and the effectiveness of the yield prohibition.
Unlike conventional comment letters that remain at the level of policy argument, the submission supplies working proof. Auditchain has expressed both proposed forms as complete, Financial Data Transparency Act Joint Data Standards-ready logical models that incorporate every schedule of the OCC’s proposal plus three additional BNP schedules.
The models carry machine-enforceable validation rules. Live, browser-accessible versions of both models are published and available for immediate inspection by OCC staff without software installation or account creation
Each model contains structure, labels, authority references (to GENIUS Act sections and the OCC’s own instructions), calculation relationships, dimensional axes, and executable validation logic. Agency staff can navigate schedules, inspect rules in plain English, and observe validation results directly in the browser.
“The collection as proposed by OCC collects reserve and activity data but has no mechanism to detect when a filing violates the collection’s own stated expectations, including the one-to-one backing requirement,” said Jason Meyers, Lead Architect of Auditchain Labs AG. “We have already built the taxonomies, the 197 rules, and the live models. The OCC does not need to invent the infrastructure; it only needs to specify it.”
The comment incorporates by reference six prior Auditchain filings with the OCC, FDIC, and NCUA between February and May 2026 that developed the same BNP framework. Independent support for the disclosure has also been expressed by XBRL US in letters to the NCUA and FDIC, and the framework has been examined by the Rutgers Continuous Auditing & Reporting Lab.
An accompanying Exhibit A provides a specification of both taxonomies and enumerates all validation rules. Exhibit B transmits a to be transmitted parallel letter to the Chairmen of the Senate Banking and Agriculture Committees proposing statutory codification of ongoing, machine-readable BNP disclosure through an amendment to the Digital Asset Market Clarity Act of 2025 and amendment to the GENIUS Act.
Auditchain Labs AG is a provider of global standards based regulatory disclosure automation and validation infrastructure. Pacioli.ai enables disclosure infrastructure and instance development as well as internal and external validation. Pacioli.ai enables organizations to prepare financial and non-financial disclosure models and export them in any data format, including XBRL and iXBRL, as required under capital markets legislation.
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