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The U.S. Department of the Treasury has concluded the comment period for the Advance Notice of Proposed Rulemaking (ANPRM) to implement the landmark Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act.
The ANPRM, issued on September 19, 2025, closed for public comment on November 4, 2025, receiving 403 comment letters from a broad spectrum of stakeholders. The comments underscore deep divisions within the financial sector, particularly concerning the prohibition of interest on stablecoins and the balance between federal and state regulatory authority. Treasury will now analyze the submitted feedback for future rulemaking.
The public comments revolved around several critical provisions of the GENIUS Act, revealing conflicting industry priorities:
- The Interest Prohibition: The Act
broadly prohibits the payment of interest or yield on stablecoins
issued by a "permitted stablecoin issuer."
- Banking groups advocated for a broad interpretation, urging the Treasury to prohibit all forms of yield or benefits on stablecoins to prevent regulatory arbitrage and maintain consumer protection standards consistent with traditional banking.
- Crypto industry argued for a narrower application, asserting the prohibition should only apply to the issuer itself, thus allowing third-party platforms or affiliates to offer rewards on stablecoin holdings.
- Federal vs. State Oversight: The Conference of State Bank Supervisors continues to stress the importance of preserving state oversight and allowing issuers the choice between federal and state chartering, respecting existing state-level frameworks.
- Consumer Protection & Illicit Finance:
- Consumer Reports emphasized the need for safeguarding stability and consumer trust, drawing clear boundaries between payments and investments and ensuring truthful marketing and unified oversight. They specifically opposed offering any yield on stablecoin holdings, fearing that consumers may be motivated to chase higher yields and move away from safer, FDIC-insured investments.
The significant volume and complexity of the comments signal a challenging road ahead for the Treasury. Organizations involved in the digital asset space must proactively prepare for the forthcoming Notice of Proposed Rulemaking (NPRM). The final regulations are expected to reshape competition between traditional finance and emerging digital players.
We will continue to monitor the Treasury's progress and provide updates as the NPRM is released.
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