Bank Policy Institute and Clearing House Association Submit Comments Supporting OCC Stablecoin Supervision Standards

On July 24, 2026, the Bank Policy Institute and The Clearing House Association submitted comment letters supporting the OCC's proposed payment stablecoin supervision standards. While backing strong AML/CFT rules aligned with FinCEN and OFAC, the groups urged regulators to coordinate under the GENIUS Act, extend public comment timelines, clarify consumer protection laws, mandate explicit fraud risk frameworks, and enforce consistent liquidity stress testing.

OCC stablecoin supervision proposal

• ▪The Bank Policy Institute and The Clearing House Association filed a joint comment letter on July 24, 2026, supporting the Office of the Comptroller of the Currency's proposed payment stablecoin requirements.
• ▪The Bank Policy Institute filed a standalone comment letter on July 24, 2026, reiterating suggestions regarding non-AML/CFT supervisory issues for stablecoin issuers.

AML/CFT regulatory requirements

• ▪The Bank Policy Institute and The Clearing House Association support the proposed consultation requirement with FinCEN regarding enforcement actions or significant AML/CFT supervisory actions.
• ▪The Bank Policy Institute and The Clearing House Association expressed support for the Office of the Comptroller of the Currency's proposal that stablecoin issuers must abide by obligations established by FinCEN and OFAC.
• ▪The Bank Policy Institute and The Clearing House Association support the proposed standard providing that payment stablecoin issuers would not face AML/CFT enforcement actions absent a significant or systemic program failure.

Consumer protection clarification needs

• ▪The Bank Policy Institute noted that consumer protection laws and their application to stablecoin issuers are currently unaddressed in the GENIUS Act.
• ▪The Bank Policy Institute urged the Office of the Comptroller of the Currency to coordinate with other federal regulators to clarify how consumer protection laws, such as Regulation E and the Gramm-Leach-Bliley Act, apply to payment stablecoin issuers.

Fraud risk management frameworks

• ▪The Bank Policy Institute urged regulators to recognize fraud risks more explicitly to protect consumers and the financial system from stablecoin-related fraud disputes.
• ▪The Bank Policy Institute recommended that the Office of the Comptroller of the Currency require payment stablecoin issuers to address fraud risks explicitly within their risk management frameworks.

Liquidity standards for issuers

• ▪The Bank Policy Institute stated that the Federal Deposit Insurance Corporation's proposed approach to stablecoin redemption in stress is less conducive to run dynamics than the Office of the Comptroller of the Currency's approach.
• ▪The Bank Policy Institute recommended that the Office of the Comptroller of the Currency require payment stablecoin issuers to maintain consistent liquidity standards and account for redemption surges through mandatory stress tests.

GENIUS Act implementation coordination

• ▪The Bank Policy Institute and The Clearing House Association urged federal agencies implementing the GENIUS Act framework to coordinate their rulemaking efforts.
• ▪The Bank Policy Institute and The Clearing House Association expressed concern that the public comment period on the Office of the Comptroller of the Currency's stablecoin proposal was too short.

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