ConsenSys has recently shared a detailed comment letter that was submitted this week focused on key stablecoin ecosystem developments. Blockchain infrastructure provider ConsenSys offered constructive feedback on the Office of the Comptroller of the Currency’s (OCC) proposed regulations for payment stablecoins under the GENIUS Act.
While acknowledging the agency’s overall approach to a complex challenge, the blockchain focused firm highlighted three key areas where refinements could better support innovation, competition, and clarity in the emerging stablecoin market.
The GENIUS Act explicitly bars stablecoin issuers from offering interest or yield directly to holders.
Lawmakers aimed to prevent these digital assets from functioning like interest-bearing bank deposits, which are funded by the reserves that back the coins. ConsenSys fully supports this congressional intent.
However, the OCC’s draft rules extend the prohibition to “related third parties.”
As written, this broad category could unintentionally capture independent distributors—such as wallet providers or white-label partners—that co-brand a stablecoin and use their own commercial fees to offer user incentives. ConsenSys argues this goes beyond what Congress intended.
Distributors spending their own revenue on customer acquisition are simply competing in the marketplace, not siphoning reserve earnings.
Lawmakers twice rejected amendments that would have widened the ban to non-issuers, and the final rule should honor that clear boundary.
A second concern involves decentralized finance (DeFi) integration. When users move stablecoins into protocols like Aave or Morpho via a non-custodial wallet such as MetaMask, they are making an active investment choice.
They accept protocol-specific risks and earn returns generated by borrowers within that ecosystem—not from the stablecoin issuer itself.
The GENIUS Act already excludes non-custodial software interfaces from regulated intermediary status.
ConsenSys urges the OCC to explicitly confirm that this carve-out extends to DeFi access, preserving users’ ability to participate in open lending markets without triggering issuer-yield restrictions.
The third recommendation addresses multi-brand arrangements. The OCC is weighing a prohibition on a single licensed issuer supporting multiple co-branded stablecoins.
ConsenSys believes targeted transparency offers a more balanced solution. Issuers could be required to clearly disclose their identity and the structure of reserve pools for each brand.
If additional safeguards are needed, segregated reserve pools per brand would provide a proportionate structural fix.
An outright ban, by contrast, would eliminate a viable distribution model rather than mitigate its risks.
It could also create an uneven playing field, placing OCC-supervised issuers at a disadvantage compared with those under FDIC oversight, which face no similar limitation.
Stablecoin issuance and distribution remain in their formative stages.
The regulatory framework finalized now will shape whether the sector evolves into a vibrant, competitive payments infrastructure or consolidates among a handful of large institutions capable of absorbing every compliance burden internally.
It will also influence how U.S.-regulated stablecoins compete globally against offshore alternatives.
By focusing on precision rather than overreach in these three areas, ConsenSys contends that regulators can foster responsible growth while upholding the core safeguards Congress established. The firm concluded by acknowledgding the OCC’s thoughtful proposal and looks forward to continued dialogue as the rules move forward.