✓ Official source
Blockchain Association asks Treasury to narrow its GENIUS Act stablecoin rule for DeFi, market makers and foreign issuers
Summary
The Blockchain Association filed a 26-page comment letter on Oct. 19 on the U.S. Treasury’s proposed rule implementing Section 3 of the GENIUS Act, which governs who can issue, offer and sell payment stablecoins in the U.S.
The industry group said it supports Treasury’s core goal of safe stablecoins issued by regulated companies with adequate reserves, but asked for clearer limits on who counts as a digital asset service provider, saying firms trading for their own account, including on decentralized venues, should not be swept in.
It also asked Treasury to require actual knowledge and substantial assistance before anyone faces criminal liability for “knowing participation” in an unlawful issuance, to let firms rely on regulators’ public lists instead of open-ended due diligence on foreign issuers, and to replace a “reasonably believes” location test with one based on actual knowledge.
The comment period closed Monday with 123 submissions, according to the federal regulations portal, The Block reported.
Key facts
- The letter, addressed to Treasury Acting General Counsel Rachel Miller, responds to the proposed rule published at 91 Fed. Reg. 53,368 on Aug. 18, 2026 (docket TREAS-DO-2026-0496).
- The letter says ordinary market-making, distribution or secondary-market activity should not count as participation in an unlawful issuance, and that the rule should not in practice accelerate the July 18, 2028 compliance date Congress set for DASPs.
- The group asked Treasury to rule out an open-ended “functional equivalent” test for monetary value in the payment stablecoin definition, revisit its cost estimates, and align the effective date with related GENIUS Act rules.
- The Block said the GENIUS Act, signed into law last year, is expected to take effect in January 2027.