The Institute of International Bankers submitted a comment letter urging the Office of the Comptroller of the Currency to tailor GENIUS Act reporting requirements for foreign payment stablecoin issuers. It argued that reporting should focus on information reasonably necessary to assess issuers’ US payment stablecoin activities and compliance, rather than applying the same framework to foreign and domestic issuers. The group recommended allowing foreign issuers to use reasonably equivalent home country regulatory reports and accounting standards. It also called for an appropriate process to request confidential treatment, greater flexibility for amended reports and technical changes to improve the accuracy and workability of the proposed framework.