Attion Consulting welcomes the opportunity to participate in the rulemaking process for the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).
Our comment letters on pending regulations ask a practical question: can an issuer design a payment product, redeem it at par, disclose it clearly, and sit inside or alongside a bank without stepping on a prohibition the statute did not intend to create?
We support the core statutory choices: no yield on the token, regulated issuance, timely redemption, and safety-and-soundness supervision. Attion's comments ask regulators to make those choices workable: use historical banking interpretations instead of inventing a parallel vocabulary; say what is integral to the stablecoin relationship and what is an additional paid product; keep disclosures short enough to be understood; allow a parent to support an issuer in stress; and keep deposit insurance and tokenized deposits technology-neutral until the market has taken shape.
Across Attion's four letters, we focus on:
- Interest and yield, using historical Regulation Q principles rather than a new set of definitions
- Redemption mechanics that support institutional acceptance: timing, access, minimums, and reserve-based rather than market-price triggers
- Disclosures that create confidence without burying the customer in legal terms
- The boundary between a stablecoin relationship and a tied or bundled bank product
- Enabling parent companies to support PPSI subsidiaries in times of stress
- Application burden, interagency consistency, and a measured approach to tokenized deposits and incentive compensation
The full text of the letters is available below:
- OCC: Implementing the GENIUS Act, May 1, 2026: Interest-or-yield definitions, PPSI application predictability, redemption design, short-form disclosures, and why a full bank-style incentive-compensation regime is premature. https://www.regulations.gov/document/OCC-2025-0372-0001
- FDIC: Approval Requirements for Issuance of Payment Stablecoins, May 18, 2026: What belongs in the subsidiary-issuer application, and why communications readiness during digitally accelerated confidence events is an operational-resilience issue rather than a social-media compliance add-on. https://www.fdic.gov/federal-register-publications/attion-consulting-llc-alyson-stone-rin-3064-ag20.pdf
- FDIC: Requirements and Standards for PPSIs, June 9, 2026:
Activities, redemptions, risk management, parent support, pass-through insurance aggregation, and technology-neutral deposit insurance for tokenized deposits. https://www.fdic.gov/federal-register-publications/comments-rin-3064-ag19-april-10-2026#:~:text=29.%20ATTION%2C%20Alyson%20Stone%20(PDF)
- NYDFS: Authorized Payment Stablecoin Issuers, September 21, 2026: How the GENIUS Act tying prohibition and existing Section 106 / Regulation Y rules apply when a New York bank and a PPSI subsidiary share customers, plus short-form disclosures and affiliate-transaction standards that still allow safe and sound parent support in stress.
We believe these contributions advance responsible innovation while reinforcing the safety and soundness foundations that have long defined U.S. financial regulation.
We welcome dialogue with regulators, industry participants, and other stakeholders on these important topics.