The Blockchain Association filed a comment letter with the US Department of the Treasury on October 19, 2026, the final day for public input on the proposed rule on payment stablecoins. The association supports Treasury’s proposal implementing Section 3 of the GENIUS Act, while requesting modifications in four main areas: the definition of digital asset service providers, criminal liability standards, treatment of foreign issuers, and location-based tests for decentralized systems. It also called for dropping the open-ended functional equivalent test, revising compliance cost estimates, and aligning effective dates with related regulations. The GENIUS Act, signed on July 18, 2025, creates a federal framework for payment stablecoins and is set to take effect on January 18, 2027, or 120 days after final rules are enacted.
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