Joint Trades Request Extension of Comment Period for Approval Requirements NPR

Dear Ms. Jones:

The American Bankers Association, the Bank Policy Institute, The Clearing House
Association, the Consumer Bankers Association, and the Independent Community Bankers of
America^[1] request that the FDIC extend the deadline for public comments on the Notice of
Proposed Rulemaking referenced above (the "Approval Requirements NPR") by the later of (i)
60 days or (ii) 30 days after the issuance by the FDIC of an NPR to implement the capital,
liquidity, risk management, and other requirements under section four of the GENIUS Act for
permitted payment stablecoin issuers ("PPSIs") that are subsidiaries of insured depository
institutions.

The Approval Requirements NPR would implement the application provisions of the
GENIUS Act for FDIC-supervised depository institutions to issue payment stablecoins through a
subsidiary. The NPR was released on December 16, 2025, and published in the Federal Register
on December 19, 2025. Comments are due to the FDIC by February 17, 2026.

The FDIC has not yet issued a proposal to implement the capital, liquidity, risk management, and other prudential requirements, as required by section four of the GENIUS Act, that would apply to PPSIs that are subsidiaries of FDIC-supervised institutions. Our comments on the Approval Requirements NPR would be more comprehensive-and therefore more useful to the FDIC-if we could consider simultaneously the proposed substantive requirements that the FDIC would evaluate under this approval process.^[2]

In addition, the undersigned associations as well as other stakeholders involved in the digital asset ecosystem need sufficient time to consider how this NPR would interact with the GENIUS Act's complex and novel regulatory framework for payment stablecoins. The Approval
Requirements NPR is one of dozens of interrelated rulemakings required by Congress to
implement the GENIUS Act. We appreciate the FDIC's effort to undertake this rulemaking quickly, but this regulation and the related ones required to be issued by other agencies can effectively achieve Congress' policy goals only if affected parties are given the opportunity to thoughtfully consider all required rulemakings applicable to payment stablecoins holistically.

For these reasons, we respectfully request an extension of the comment period as proposed above, which would better allow us and other interested members of the public to prepare carefully considered and well-informed comments on the Approval Requirements NPR.

We appreciate the opportunity to comment on the Approval Requirements NPR and your
consideration of our request. If you have any questions, please contact Drew Ruben by email at
[email protected].

To read the full comment letter, please click here, or click on the download button below.

[1] Please see Appendix Afor a description of the undersigned associations.

[2] The Federal Reserve Board and Office of the Comptroller of the Currency also have not proposed regulations to implement the approval standards for PPSIs within their respective remits, notwithstanding that section 5(h)(2) of the GENIUS Act requires the primary Federal payment stablecoin regulators to coordinate the issuance of such regulations. We believe interested members of the public would benefit from the opportunity to review these proposals together, particularly to ensure that the agencies propose to take a consistent, risk-based approach to evaluating PPSI applications.