Implementing the GENIUS Act for Main Street

NABA’s Response to the OCC’s Notice of Proposed Rule Making

The North American Blockchain Association (NABA) represents a distinct and often underrepresented segment of the digital asset ecosystem: smaller, state-regulated stablecoin issuers and trust companies with direct ties to local and regional economies. Unlike large, globally scaled issuers, these participants are embedded in their communities, working closely with local banks, businesses, and consumers. NABA’s response reflects this perspective, focusing on how federal stablecoin policy can support innovation and financial access at the community level while maintaining strong regulatory standards.

The following comment letter was thoughtfully crafted with our unique stakeholders in mind. We thank the OCC for the opportunity to voice the views, ideas, concerns of our member organizations as it relates to the implementation of this landmark legislation.