Circle Internet Group (NYSE: CRCL) disclosed on May 5 that it had submitted comments on May 1 to the Office of the Comptroller of the Currency (OCC) regarding the regulator’s proposed GENIUS Act rule. The filing supports a national licensing regime for payment stablecoins and clearer oversight standards for dollar-backed digital payment instruments. Circle emphasized requirements such as reliable redemption, operational resilience, and 24/7/365 functionality, while also stating that regulated payment stablecoins should remain transferable, fungible, and usable across customers, platforms, and markets.
Circle’s Core Ask: Uniform Prudential Rules
Circle wrote: “The OCC’s rulemaking turns the GENIUS Act into a durable framework that works in practice, requiring issuers to meet highest-level standards of a standalone, ring-fenced entity with all of the capacity to meet the large demands placed on global issuers.” The company argued that issuers should compete under common prudential rules, including bank, nonbank, state, federal, domestic, and foreign issuers. Circle warned that uneven standards could weaken trust, create arbitrage, and disadvantage compliant firms. The point is that stablecoin oversight should not depend on issuer type or charter path.
Key Elements of the OCC Proposal
The OCC’s proposal would apply to national banks, federal savings associations, federal branches, foreign issuers, and certain state-qualified payment stablecoin issuers under its jurisdiction. Most requirements would reside in a new 12 CFR 15, covering reserves, redemption, risk management, supervision, custody, applications, and operational backstops. The OCC also noted that anti-money laundering and sanctions-related rules would be addressed separately with the Treasury Department. Circle said the final framework should support global standards for trusted digital dollars while preserving transferability and reliable redemption. The company also called for oversight covering credit, liquidity, operational, and anti-money laundering risks. Circle stated: “With clear, practical, and consistently applied rules, the United States can protect consumers, build the market of the future, and strengthen the role of trusted digital dollars in the global economy.”
Industry Impact
This comment is part of the OCC’s public consultation on the GENIUS Act rulemaking. If finalized, the rules would provide a unified federal regulatory pathway for stablecoin issuers, potentially reshaping competition in the U.S. and global stablecoin markets. Circle, as the issuer of USDC, is pushing for regulatory certainty to solidify its market position. Analysts believe uniform rules could reduce regulatory fragmentation and attract more institutional participation, but also impose higher compliance requirements on issuers.