GENIUS Act NPRM Comment Period Closes With 105+ Industry Responses
The comment period for the GENIUS Act NPRM closed Monday, October 19, 2026, ending the primary public-feedback phase for Treasury’s stablecoin rulebook. The proposal – published in the Federal Register on August 18 as document 2026-16796 – drew more than 105 comments, with 77 visible on regulations.gov when the docket was counted, reflecting the urgency Treasury Secretary Bessent flagged in the August 17 press release.
The filing record reads like a guest list of the industry’s fault lines: the Bank Policy Institute, the American Bankers Association, Paradigm, Coinbase and Circle all filed detailed responses. The docket also logged ex parte meetings – the Digital Chamber with Societe Generale on October 1, and a separate engagement involving David Ji and Thomas Ziolkowski on October 8 – both posted October 14.
The nastiest fight is over the yield prohibition. The NPRM does not directly implement Section 4(a)(11), but the industry split cleanly on where rewards end and interest begins. Banking trade groups – the ABA and BPI – want a broad reading that would capture rewards generated by affiliates, exchanges or third-party platforms. The American Bankers Association estimates the proposed rules could trigger a 25.9% reduction in deposits and roughly $1.5 trillion in lost lending capacity, figures contested by conflicting Federal Reserve research. Coinbase, Circle and the Chamber of Digital Commerce counter that Congress deliberately limited the prohibition to payments made by the issuer. Both camps dislike the OCC’s proposed rebuttable presumption – for opposite reasons, which is usually how you know a compromise is somewhere in the middle.
The second fault line is the foreign-issuer compliance vacuum. Under Section 3 of the act, digital asset service providers face a strict enforcement deadline of January 18, 2027. Without a clear comparability path for foreign payment stablecoin issuers, firms are left navigating penalties that include civil fines of $100,000 per day and criminal exposure of up to $1 million and five years. Commenters zeroed in on the timing gap between when the foreign-issuer prohibitions bite and when any compliance pathway actually becomes available – with a Regulation S-style safe harbor floated as one fix.
Treasury’s final-rule timing remains unknown, and the calendar is not kind. "The industry is now looking toward the January 18, 2027, enforcement date," a Digital Chamber spokesperson said as the docket closed. The SEC’s Regulation Crypto Assets comment deadline, which followed on October 20, has since passed as well – leaving two of the heaviest U.S. crypto rulemakings sitting in review at the same time, with issuers, exchanges and banks waiting on both.
Source: forkast.news – Treasury NPRM Comment Period Closes TODAY: What the Industry Filed Before the GENIUS Act Deadline; Federal Register document 2026-16796 (published August 18, 2026). Comment tally per Forkast’s docket count – Treasury does not publish an aggregate figure.
