TDC Rulemaking
Response Tracker
The GENIUS Act was signed into law on July 18, 2025. Track The Digital Chamber's responses to every agency rulemaking proposal as the industry shapes the first comprehensive federal stablecoin framework.
ANPRM on GENIUS Act Implementation & Stablecoin Regulation
TDC's response to the GENIUS Act's Advanced Notice of Proposed Rulemaking (ANPRM) advocates for proportional, technology-neutral rules that clarify the statute's scope, preserve innovation, and avoid regulatory overreach during implementation.
Approval Requirements for Stablecoin Issuance by Subsidiaries of FDIC-Supervised Institutions
In our comments on the FDIC Stablecoin Issuer Rule, TDC supported alignment with the GENIUS Act while recommending targeted clarifications to constrain discretion, reinforce approval as default, and enhance procedural clarity.
Implementing the GENIUS Act for Stablecoin Issuance by OCC-Supervised Entities
In four comprehensive comment letters on the OCC’s GENIUS Act implementation rulemaking, totaling 100+ pages, TDC advocated for the OCC to remain grounded in the statute’s letter and spirit while ensuring definitional alignment across prudential regulators and preserving competition among state, federal, and international issuers.
Licensing and Investment Requirements for Credit Union-Affiliated Stablecoin Issuers
In TDC's comment we urged the NCUA to coordinate with the FDIC and OCC to establish a uniform regulatory framework across all primary federal payment stablecoin regulators to avoid fragmentation, maintain competitive neutrality, and facilitate seamless interoperability.
State-Level Regulatory Regime Equivalence Under the GENIUS Act
In our comments to Treasury, TDC advocated for preserving the GENIUS Act's dual-track framework by anchoring the federal benchmark to OCC rules, prioritizing "substantial similarity" over "meet or exceed" standards, and applying outcomes-based assessment to maintain regulatory flexibility for state-level issuers.
Requirements and Standards for FDIC-Supervised Stablecoin Issuers and Depository Institutions
In our comprehensive comments to the FDIC, TDC advocated for principles-based requirements, definitional and supervisory consistency across primary regulators, flexibility to accommodate innovation, and safeguards against prescriptive rules that could undermine the statute's competitive and federalist design.