BAFT Comment Letter on Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency
BAFT’s response to the GENIUS Act emphasizes the need for a balanced regulatory framework that supports innovation in payment stablecoins while preserving financial stability and trust. The paper highlights the importance of clear definitions, risk-based supervision, and operational flexibility to enable banks and regulated institutions to participate safely in the evolving digital asset ecosystem.
It calls for pragmatic guardrails around reserve management, customer protection, and permissible activities—ensuring stablecoins can enhance cross-border payments, strengthen liquidity, and support real economic activity without introducing systemic risk.