TLDR
The Blockchain Association filed a 26-page comment letter with the U.S. Treasury on October 19, 2026, about its GENIUS Act stablecoin rules.
The group wants validators, self-custody software, and firms trading their own assets kept out of the definition of Digital Asset Service Providers.
It asked Treasury to limit liability to cases involving actual knowledge and substantial help to an issuer.
For foreign issuers, it wants firms to rely on regulators’ public prohibition lists instead of open-ended due diligence.
The comment period closed with 123 submissions, and the framework takes full effect on January 18, 2027.
The Blockchain Association has asked the U.S. Treasury Department to change its proposed stablecoin rules under the GENIUS Act. The crypto industry group filed a 26-page comment letter on October 19, 2026.
The letter responds to Treasury’s proposed rule on the issuance, offering, and sale of payment stablecoins. The framework is set to take full effect on January 18, 2027.
The group said it wants the final rule to stay faithful to “what Congress wrote.” It said it supports Treasury’s main goal of safe, reserve-backed stablecoins issued by regulated firms.
What the Blockchain Association Asked For
The letter raised three main concerns. The first deals with how the rule defines Digital Asset Service Providers, known as DASPs.
The group argued that Congress defined DASPs as businesses that serve customers. It said firms trading their own assets should not fall under that label.
The letter also said core infrastructure, such as validators and self-custody software, should be left out. The group warned that a broad reading would put compliance burdens on entities Congress did not intend to cover.
The second concern involves a proposed “knowing participation” standard. As written, the group said, ordinary secondary-market trading or market-making could carry criminal penalties.
The group asked Treasury to limit liability to cases involving “actual knowledge and substantial assistance in coordination with the issuer.” Firms have warned that unclear liability rules could discourage market-making as the January 2027 date gets closer.
The third concern covers foreign stablecoin issuers. The group opposed open-ended due diligence rules, noting that many DASPs have no direct relationship with those issuers.
Instead, it proposed letting firms rely on regulators’ public prohibition lists. This would use a standard based on actual knowledge rather than a broader “reasonably believes” test.
The letter also asked Treasury to reject an open-ended “functional equivalent” test for monetary value. It called for the rule’s effective date to line up with related GENIUS Act rules from other agencies.
Stablecoin Market and Wider Rulemaking
The total stablecoin market is valued at about $302 billion. Tether’s USDT holds about $183 billion, while USDC holds about $73 billion.
Both tokens trade widely in global secondary markets. In those markets, DASPs often see only wallet addresses rather than details about the issuer.
The rulemaking now spans several agencies. The Federal Reserve has also released two proposals for stablecoin issuers covering reserves, capital, and custody.
Regulators had already pushed back the statutory GENIUS Act deadline. The U.S. has also been briefing the United Kingdom on how the law is being put in place.
Other industry activity has surrounded the law. Earlier, 125 crypto firms defended stablecoin rewards against pushback from banks.
Separately, a firm tied to Bo Hines received $6.3 million from Tether while he helped shape the law, which drew criticism. The Trump administration has also weighed promoting dollar-backed stablecoins overseas.
The public comment period closed on October 19 with 123 total submissions. Treasury will now review them before issuing a final rule.
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