Circle, an issuer of U.S. dollar payment stablecoins, has formally responded to federal regulators with a comprehensive set of recommendations aimed at refining the implementation of a new national licensing system for digital payments. In its submission dated May 1, 2026, the company outlined constructive technical insights and strategic principles designed to support a robust, practical structure for dollar-backed stablecoins.
The proposed framework originates from the GENIUS Act, landmark legislation passed by Congress to create the United States’ first dedicated regulatory system for payment stablecoins.
At its core, the Act requires issuers to maintain substantial reserves, guarantee consistent redemption rights, adopt comprehensive risk controls, undergo rigorous oversight, and uphold the highest levels of operational compliance.
To translate these congressional goals into actionable policy, the Office of the Comptroller of the Currency (OCC) recently published a Notice of Proposed
Rulemaking that spells out detailed expectations around reserve handling, cybersecurity protections, intensive risk protocols, adequate staffing and infrastructure, and continuous 24/7/365 service capabilities tailored for large-scale, institution-level digital finance providers.
This initiative seeks to embed payment stablecoins firmly within the global financial architecture, ensuring they remain safe, fully transparent, readily redeemable, and worthy of confidence from everyday users, corporations, banks, and supervisors.
Issuers would operate as independent, fully segregated entities capable of scaling to meet worldwide demand without compromising stability.
By extending US regulatory rigor and legal protections internationally, the regime aims to establish a worldwide gold standard for trusted digital dollars.
Notably, the Act explicitly separates payment stablecoins—optimized for broad, frictionless transfers and final settlement—from tokenized bank deposits, which remain outside its scope because they function as direct representations of bank liabilities and serve narrower purposes.
In its comment letter, Circle praises the OCC’s rulemaking as a critical milestone that will help realize the GENIUS Act’s vision and lay the foundation for a competitive, national-grade payments network.
The firm argues that clear, well-crafted rules are vital for protecting consumers, enabling responsible technological progress, and reinforcing U.S. dominance in digital finance.
Central to its position is the conviction that American standards should set the global benchmark, exporting the benefits of strong US oversight while preventing market fragmentation.
Circle warns that any divergence in how stablecoins are issued or transferred across platforms could erode liquidity, undermine redeemability, and heighten systemic vulnerabilities.
Consumer confidence remains paramount, the letter stresses, because holders must be assured of instant, reliable access to their funds no matter where they are located.
To build a durable market, regulators must bar unqualified entities from claiming “stable” status without proper supervision.
Circle also advocates for a level playing field that applies uniformly to every issuer—whether bank or non-bank, domestic or foreign, state- or federally chartered—eliminating opportunities for regulatory arbitrage that could disadvantage compliant players and weaken overall trust.
Risk management standards, the company adds, must reflect the instruments’ primary role in payments and settlements, addressing credit, liquidity, concentration, operational, and compliance exposures rather than treating stablecoins as simple technology experiments.
Circle urges the OCC to finalize a set of clear, workable, and evenly enforced requirements that safeguard users, nurture emerging markets, and elevate the global standing of trusted digital dollars. If implemented thoughtfully, the GENIUS Act licensing regime will not only protect American consumers but also drive responsible innovation and solidify the US dollar’s leadership in the digital economy.