Key Highlights

  • Five major US banking groups called for over 60 extra days on three interdependent regulatory comment periods tied to the GENIUS Act stablecoin framework.

  • The groups argue the current comment schedule is unworkable because Treasury, FDIC, and FinCEN rules are all directly contingent on the OCC's final framework.

  • They submitted seven specific recommendations opposing stablecoin yield payments and pushing for stricter reserve disclosures, consumer protections, and limits on commercial entities issuing stablecoins.


The Guiding and Establishing National Innovation for US Stablecoins Act, signed into law in July 2025, is moving into its implementation phase and running into its first organised resistance from the traditional banking sector. 


Five industry groups, the Bank Policy Institute, American Bankers Association, Consumer Bankers Association, Financial Services Forum, and The Clearing House, have asked regulators to push back overlapping comment periods for three separate rule sets being developed in parallel under the act.


Three agencies are writing rules simultaneously: Treasury is determining state regulatory equivalency, the FDIC is setting standards for FDIC-supervised stablecoin issuers, and FinCEN and OFAC are drafting joint anti-money laundering and sanctions compliance requirements.


All three, the banking groups argue, depend on the OCC's foundational permitted payment stablecoin issuer framework, which will not be finalised until July 2026. Commenting on downstream rules before the upstream framework is settled means any input risks becoming obsolete the moment the OCC publishes.


The groups described the current setup as "a fragmented comment process with staggered, compressed deadlines across interdependent proposals" that works against the agencies' own stated goal of regulatory consistency.


The broader policy positions the groups submitted go further than process timing. The coalition wants yield payments on stablecoins banned across all issuers, not just the banks and licensed nonbanks designated as permitted payment stablecoin issuers under the act. 


The GENIUS Act set a compliance deadline of either January 18, 2027 or 120 days after final rules are published, whichever comes first. With the OCC targeting July 2026 for its final rule, the window between final framework and mandatory compliance is already compressed. 


Whether regulators grant the extension the banking groups are seeking will shape how much runway non-bank stablecoin issuers, including established players like Tether and Circle, have before the new regime takes full effect.