Institute of International Bankers submits OCC comment letter seeking foreign bank parity in GENIUS Act stablecoin rules

The Institute of International Bankers submitted a comment letter on the Office of the Comptroller of the Currency's proposed rule to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act, focusing on the U.S. operations of internationally headquartered financial institutions. It argues that foreign bank groups and their U.S. operations should be able to participate in the payment stablecoin market on terms comparable to domestic institutions, consistent with national treatment and equality of competitive opportunity. Key recommendations include allowing permitted payment stablecoin issuers to hold reserves as demand deposits at insured and uninsured U.S. branches of foreign banking organizations and to use uninsured deposits, including those held at uninsured U.S. branches, to meet operational backstop requirements. The letter also calls for parity in licensing, custody and regulatory treatment, a supervisory approach for foreign payment stablecoin issuers that is more closely aligned with the OCC's narrower statutory role and limited to their U.S. payment stablecoin activity, explicit authorization of non-USD reserve assets for permitted issuers of non-USD payment stablecoins to address asset-liability mismatch risk, and publication of application and reporting forms for public comment.