Comment Letters

Attion Consulting is an active participant in federal rulemaking under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).

Drawing on two decades of hands-on experience designing and operating non-interest-bearing deposit franchises, structuring middle-market and institutional banking relationships, and building regulated financial platforms, our comment letters bring a practitioner’s perspective to the proposed rules. 

We focus on the real-world implications for product design, operational mechanics, application processes, transparency, and disclosures. Above all, we focus on the safety and soundness of the U.S. banking system and the long-term stability of the payment stablecoin market.

Across our submissions we address critical practical issues, including:

• Clear, workable standards for the prohibition on interest or yield (drawing on historical Regulation Q interpretations and principles-based guidance)
• Transparency, predictability, and burden minimization in the Permitted Payment Stablecoin Issuer (PPSI) application process
• Redemption timing, de-pegging scenarios, redemption access, and minimums
• Disclosure requirements that support market confidence without unnecessary complexity
• Operational resilience, communications readiness during digitally accelerated confidence events, and the integration of payment stablecoin activities within the regulated banking system
• Appropriate governance of incentive compensation and risk management frameworks

The full text of our two comment letters is available below:

• May 1, 2026 comment letter to the Office of the Comptroller of the Currency (implementing the GENIUS Act for the issuance of stablecoins by entities subject to OCC jurisdiction): https://www.regulations.gov/document/OCC-2025-0372-0001
• May 18, 2026 comment letter to the Federal Deposit Insurance Corporation (approval requirements for issuance of payment stablecoins by subsidiaries of FDIC-supervised insured depository institutions)

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.​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​​