https://njump.me/nevent1qqsg8n09q7lkdl3dg4j7ha59ja8ye25jzs8grce5klc8v0chk704ltsntmj62
The (BlockchainAssn) is arguing that customer identification rules for stablecoin issuers under the GENIUS Act should only apply to primary market activity, not secondary market.
Their position is that if stablecoins are sent peer-to-peer after issuance, the issuer has no visibility into the transaction and no technical ability to identify the parties involved.
They're also arguing that one-off redemptions shouldn't trigger full account status, comparing it to cashing a check at a bank rather than opening an account.
On identity verification, they want issuers to have the flexibility to use digital wallets, verifiable credentials, and zero-knowledge proofs instead of requiring customers to submit personal data directly. Their claim is that ZKP technology can be more reliable than traditional methods like database checks.
They're pushing for issuers to be shielded from liability when they rely on another regulated institution's KYC and that institution fails. Banks already get this protection and the Association argues stablecoin issuers should too.
They also want all the GENIUS Act compliance deadlines coordinated so issuers aren't building against a moving target as different agencies finalize rules on different timelines.
The letter is addressed to five federal agencies. FinCEN, the OCC, the Fed, the FDIC, and the NCUA.