GBBC USA Response to OCC Request for Comments | Implementing the GENIUS Act for Payment Stablecoin Issuers

GBBC USA has submitted its response to the Office of the Comptroller of the Currency’s Request for Comments on implementing the GENIUS Act for the issuance of payment stablecoins by entities subject to OCC jurisdiction. We welcome the OCC’s engagement and support the development of a clear, proportionate, and workable prudential framework for payment stablecoin issuance in the United States.

Our response recommends targeted calibration across several core areas. We encourage the OCC to adopt functional, technology-neutral definitions that reflect the economic characteristics, legal rights, and actual risk-bearing activity associated with digital assets and payment stablecoin issuance. Additionally, we recommend clarifying the concept of “control” to capture meaningful influence over governance, reserves, redemption, technology infrastructure, and third-party dependencies, not only formal ownership or voting thresholds.

On reserves and redemption, our response emphasizes reserve quality, liquidity, legal rights, operational readiness, and reliable access to assets under stress. We recommend clearer treatment of Government money market funds, repo and reverse repo arrangements, tokenized reserves, and risk-sensitive measures such as targeted buffers, haircuts, or supervisory guidance where reserve assets present valuation or monetization risks. Furthermore, we recommend a redemption framework that supports same-day or next-business-day fulfillment where feasible, treats longer stress-period timelines as exceptional, and includes strong transparency, notification, and supervisory safeguards.

Our response further recommends stablecoin-specific risk management standards addressing reserve management, redemption reliability, operational resilience, cybersecurity, custody, third-party dependencies, smart contract governance, and blockchain infrastructure risks. We also encourage the OCC to consider automated or near-real-time oversight tools for reserve composition, token supply, redemption activity, and material operational incidents.

Read the full response here.