BPI and The Clearing House Association Comment on FinCEN’s Customer Identification Program Proposal for Permitted Payment Stablecoin Issuers

Ladies and Gentlemen:

The Bank Policy Institute^[1] and The Clearing House Association^[2] (the "Associations") are writing to comment on the notice of proposed rulemaking issued by FinCEN, along with the OCC, the Board, the FDIC, and the NCUA (collectively, the "agencies") regarding the implementation of CIP obligations for PPSIs under the GENIUS Act.^[3]

The Associations are generally supportive of the proposed CIP framework. The recommendations below are intended to clarify the framework so that it operates in conjunction with the broader set of GENIUS Act implementing rules, including parallel rulemakings addressing the general regulatory framework, as well as AML/CFT and sanctions compliance,^[4] and with existing CIP requirements applicable to other financial institutions subject to the BSA.^[5] In particular, the final rule should include additional guidance regarding the explicit application of CIP requirements to customer relationships established by secondary market intermediaries; the application of CIP obligations in the context of direct redemption, including the interaction between customer onboarding and redemption requirements; and the scope and interaction of the defined terms "customer" and "account." Our recommendations are intended to support and strengthen the proposal by reducing interpretive uncertainty and facilitating effective implementation of the CIP requirements across the payment stablecoin ecosystem.

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

[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. BPI produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.

[2] The Clearing House Association L.L.C., the country's oldest banking trade association, is a nonpartisan organization that provides informed advocacy and thought leadership on critical payments-related issues. Its sister company, The Clearing House Payments Company L.L.C., owns and operates core payments system infrastructure in the United States, clearing and settling more than $2 trillion every business day.

[3] Permitted Payment Stablecoin Issuer Customer Identification Program, 91 Fed. Reg. 37,234 (June 22, 2026) (the "NPR"); GENIUS Act, Pub. L. No. 119-27, 139 Stat. 419 (2025), codified at 12 U.S.C. §§ 5901-5916.

[4] See Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements, 91 Fed. Reg. 18,582 (Apr. 10, 2026) (the "April NPR").

[5] For example, the Treasury Department recently issued a proposed rule to implement section 3 of the GENIUS Act that, among other things, addresses when an entity is deemed to "issue" a payment stablecoin. That determination may bear directly on when and how customer relationships with PPSIs are established and, in turn, when CIP obligations apply. The agencies should therefore coordinate their respective rulemakings to ensure that the resulting regulations are consistent and operate together as a cohesive regulatory framework for the payment stablecoin ecosystem, as intended by the GENIUS Act. See GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale, 91 Fed. Reg. 53,368 (Aug. 18, 2026).