The Office of the Comptroller of the Currency should propose new reporting forms for stablecoin issuers only after it has finalized regulatory requirements for those companies, and it should work with other regulators to ensure forms for all issuers are substantially similar across agencies, the American Bankers Association and Bank Policy Institute said today.
The OCC recently proposed new reporting forms for payment stablecoin issuers as part of its implementation of the 2025 Genius Act. In a joint letter, ABA and BPI offered several recommendations for how it should implement the new forms, including holding off action until the OCC has finalized its regulations for issuers.
“(T)here are significant changes that the OCC should make to aspects of its substantive rules that would materially change the reporting forms,” the associations said. “The public should have the opportunity to comment on proposed reporting forms that align with the underlying substantive regulations.”
Other recommendations include coordinating with other agencies to ensure all forms for issuers are similar to promote regulatory consistency, requiring issuers to submit quarterly reporting forms in addition to existing reporting requirements, and making a series of adjustments to the proposed weekly reporting forms.
