The Comment Window Closes on the Stablecoin Rulebook, With Final Rules Set for November
Banks, issuers and consumer groups filed their last arguments Friday on identification and anti-money-laundering standards, as regulators work through a statutory deadline they have already missed.
The comment period closed Friday on the customer identification requirements proposed jointly by federal banking regulators and the Treasury's financial crimes unit for permitted payment stablecoin issuers — the final scheduled input before the rules that will govern a $320 billion market are written.
The Office of the Comptroller of the Currency has said it is targeting November to finalize its principal rules under the stablecoin statute. The law's own deadline for implementing regulations passed in July, with about ten proposals still pending across the agencies.
What the industry argued
Issuers have pressed on three points.
Proportionality. Applying the full customer identification apparatus built for bank accounts to a payment token, they argue, imposes costs that do not scale down for small transfers and pushes ordinary users toward unregulated alternatives.
Wallet-level ambiguity. A token can move to an address whose owner the issuer never onboarded. Where the obligation sits — with the issuer, the exchange, or the wallet software — is the single most consequential unresolved question in the proposal.
Timing. Firms that have already obtained conditional charters have been building compliance programs against proposals rather than final rules, and several have asked for a transition period after the rules are adopted.
What the banks argued
The banking industry's comments have focused less on the mechanics than on the competitive frame. Trade groups have argued that entities competing for the same balances should carry comparable obligations, and that reserve deposits held at a small number of institutions concentrate funding risk in a way the framework does not adequately address.
That argument has the most political force behind it, because community banks fund local lending with local deposits, and every dollar that migrates into tokens is a dollar not available to lend.
The stakes
Two issuers account for roughly 83% of outstanding supply. Nothing in the current proposals works against that concentration, and the compliance costs being debated this week are, in practice, a barrier that favors the largest players.
Whoever finishes the rules in November will be deciding not just how a stablecoin is regulated, but how many of them there will be.
