The Institute of International Bankers has submitted a comment letter to the New York Department of Financial Services on its proposed regulation implementing the stablecoin framework established by the GENIUS Act, urging changes so the U.S. operations of foreign banks can participate on the same basis as domestic institutions. The letter frames its recommendations around the U.S. banking principles of national treatment and equality of competitive opportunity, and seeks consistency between the state proposal and federal implementation efforts. Its recommendations would allow authorized payment stablecoin issuers to hold reserves at both insured and uninsured U.S. branches of foreign banks, with uninsured deposits eligible to meet operational backstop requirements. The group also called for equal treatment of U.S. branches of foreign banks in custody and reserve services, including reserve custody arrangements and related approval requirements, asked NYDFS to take account of the existing U.S. federal framework for internationally headquartered financial institutions when reviewing applications to establish authorized payment stablecoin issuers, and supported flexible risk management and capital standards that can accommodate different legal and governance structures for foreign-owned stablecoin issuers.
Institute of International Bankers2026-06-22
Institute of International Bankers urges New York Department of Financial Services to revise stablecoin proposal for equal treatment of foreign banks
The Institute of International Bankers urged the New York Department of Financial Services to adjust its proposed stablecoin rules so U.S. operations of foreign banks can compete on the same basis as domestic firms. Its recommendations cover reserve eligibility at insured and uninsured branches, equal treatment in custody and reserve services, consideration of existing federal oversight, and flexible risk and capital standards for foreign-owned issuers.