The US Department of Treasury issued a request for comment on the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act. Read the full and detailed response of BAFT on this request for comment.
Policy News
BAFT Response to ECB Consultation to Extend T2 Operating Hours
BAFT supports extending T2 operating hours in a measured, opt-in, and phased manner to enhance liquidity management, support instant and cross-border payments, and keep traditional payment rails competitive with new technologies. However, it emphasizes that full 24/7/365 operations would impose major costs, risks, and system changes, and should only proceed with clear demand, industry alignment, and long notice periods. BAFT urges careful consideration of operational resilience, liquidity sourcing, cybersecurity, and coordination with T2S, recommending feasibility studies, staggered implementation, and safeguards like circuit breakers and central liquidity bridges.
BAFT Comment Letter to FRS/FDIC/OCC RFI on Payments Fraud
BAFT submitted a comment letter to urge regulators to expand collaboration across banks, fintechs, telecom, social media, and law enforcement — both domestically and internationally — to effectively combat payments fraud. The association calls for real-time data sharing, clearer liability standards, and safe harbor protections so banks can pause suspicious transactions without fear of penalty. It also recommends updated regulations, industry-wide fraud standards, and consumer/business education campaigns to strengthen prevention, detection, and mitigation efforts.
Position Paper on the National Transposition of Article 21C CRD VI
BAFT joined with numerous trade associations, including the Bank Policy Institute, UK Finance, the Loan Market Association, the Swiss Finance Council, and others, to urge European Union Member States to implement the branch requirements under CRD VI (Capital Requirements Directive) in a uniform and harmonized manner. This effort is part of BAFT’s overall advocacy on Basel III capital standards as they are implemented at the national level. CRD VI was, in part, the EU’s adoption of the final pieces of the Basel III Framework.
BAFT Comment Letter to the Office of Management and Budget (OMB) Regarding Deregulation
On May 12, 2025, BAFT responded to the Office of Management and Budget’s (OMB) request for information regarding Deregulation.
Click below to read the comment letter in its entirety.
BAFT White Paper on The Impact of Stablecoins on Payments
The Impact of Stablecoins on Payments
An In-Depth Analysis of How Stablecoins are Reshaping the Global Payments Ecosystem
“The Impact of Stablecoins on Payments” is a comprehensive examination of the growing role of stablecoins in domestic and cross-border payments and the implications for financial institutions, regulators, and payment service providers.
As stablecoins continue to gain traction as a digital payment instrument, their promise of near-instant settlement, reduced transaction costs, and programmability is reshaping traditional paradigms in the payments industry. The white paper explores these developments across four key dimensions:
1. Market Landscape and Use Cases
2. Risks and Operational Challenges
3. Regulatory Outlook and Compliance Considerations
4. Interoperability with Traditional Payment Systems
As a benefit to BAFT members, this whitepaper is free and available for early access to members to download before others in the industry.