The Institute of International Bankers has submitted a comment letter to the U.S. Department of the Treasury on its proposed rule for judging whether a state regulatory regime is substantially similar to the federal framework under the Guiding and Establishing National Innovation for U.S. Stablecoins Act. The group asked Treasury to explicitly account for foreign payment stablecoin issuers when setting those principles and to treat conflicts between state requirements and the federal framework as a key consideration. IIB recommends that Treasury include, as a principle in the similarity assessment, whether state requirements applicable to foreign payment stablecoin issuers impermissibly conflict with the GENIUS Act framework governing their U.S. activities. It also asks Treasury to revise the proposal so foreign payment stablecoin issuers are expressly addressed when reviewing additional state requirements and potential conflicts with federal law. In addition, the letter calls for state-level regimes affecting the U.S. operations of foreign banks to reflect national treatment and equality of competitive opportunity, particularly for stablecoin issuance, reserve and custody services, and bank capital requirements.
Institute of International Bankers2026-06-02
Institute of International Bankers urges Treasury to cover foreign payment stablecoin issuers in GENIUS Act state regime test
The Institute of International Bankers has urged the U.S. Department of the Treasury to revise its proposed rule on assessing whether state regimes are substantially similar to the federal framework under the Guiding and Establishing National Innovation for U.S. Stablecoins Act. It asks Treasury to explicitly address foreign payment stablecoin issuers in the similarity assessment, treat conflicts between state and federal requirements as a key factor, and ensure state regimes affecting foreign banks’ U.S. stablecoin activities reflect national treatment and competitive equality.