Circle Internet Group (NYSE: CRCL) has formally urged the Office of the Comptroller of the Currency (OCC) to finalize clear and consistently applied rules for payment stablecoin issuers under the proposed GENIUS Act. In comments submitted on May 1 and made public on May 5, Circle backed the OCC’s proposal for a national licensing regime.
The company argued that the framework should set strong standards for reserves, redemption, information security, and operational readiness. Circle emphasized that stablecoins must be reliably redeemable and operate 24/7/365. They should remain transferable, fungible, and usable across different customers and platforms.
Uniform Rules for All Issuers
A key point in Circle’s filing was that all issuers—bank or nonbank, state or federal, domestic or foreign—should compete under the same prudential rules. Circle warned that uneven standards could weaken trust, create regulatory arbitrage, and put compliant firms at a disadvantage. The company said oversight should not depend on an issuer’s charter path or type.
The OCC’s proposal would apply to national banks, federal savings associations, federal branches, and certain state-qualified payment stablecoin issuers. Most requirements would be housed in a new 12 CFR 15, covering areas like risk management, custody, applications, and operational backstops. Anti-money laundering and sanctions rules would be addressed separately with the Treasury Department.
Supporting Global Digital Dollars
Circle called for a final framework that supports global standards for trusted digital dollars while preserving transferability and reliable redemption. The company also highlighted the need for oversight covering credit, liquidity, operational, and anti-money laundering risks. They said the OCC’s rulemaking turns the GENIUS Act into a durable framework that works in practice.
Overall, Circle made it clear that clear, practical, and consistently applied rules can protect consumers, build future markets, and strengthen the role of trusted digital dollars globally.










