This Digital Chamber is excited to announce that we recently submitted four comprehensive responses to the Office of the Comptroller of the Currency’s (OCC) proposed rulemaking for the implementation of the GENIUS Act.
When sweeping legislation like the GENIUS Act transitions from statutory text to enforceable rules, the details matter immensely. The OCC’s rulemaking process will likely dictate the operational realities, compliance frameworks, and strategic landscapes of the digital asset industry for years to come.
When the OCC released its proposed rulemaking, it spanned almost 400 pages of dense and complex regulatory framework. Within those pages, the regulators posed 211 specific, highly technical questions to the public. We had less than 60 days to digest the text, analyze its implications, gather consensus, and draft our responses.
Over 20 TDC member companies and law firms stepped up to the plate, dedicating their time and insights to this massive undertaking, submitting over 100 pages of responsive material. Our coalition tackled the proposal head-on, providing thoughtful, detailed, and substantive feedback on almost all of the 211 questions presented by the OCC.
This achievement would have been impossible without the minds that guided us. A special thank you to the teams at Perkins Coie, Clifford Chance, and Morgan Lewis. These teams worked tirelessly around the clock to coordinate responses, synthesize diverse viewpoints from our member companies, and craft rigorously researched arguments. Their dedication, unparalleled expertise, and sheer hard work were the engines that drove this initiative across the finish line.
Together, we have not only met a massive regulatory challenge, but we have also actively shaped the future of the GENIUS Act. Thank you all for your unwavering commitment and exceptional work.
TDC Responses to OCC Rulemaking Proposal:
GROUP 1: Questions 1-24 (Definitions), 100-108 (Redemption), and 198-211 (General)
GROUP 3: Questions 44-99 (Reserve Assets) and 109-128 (Risk Management)
If you have any questions, please reach out to policy@digitalchamber.org.