Public Comments

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PUBLIC SUBMISSION

As of: 4/22/26 10:00 PM
Received: March 26, 2026
Status: Posted
Posted: March 30, 2026
Tracking No. mn8-b0ky-c23h
Comments Due: May 01, 2026
Submission Type: Web

Docket: OCC-2025-0372
Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of
Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency
Comment On: OCC-2025-0372-0001
Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by
Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency
Document: OCC-2025-0372-0034
B2BTechnique

Submitter Information
Address: United States,
Email: [email protected]
Submitter's Representative: Brandon Smith
Organization: B2BTechnique

General Comment
See attached file(s)

Attachments
B2BTechnique

file:///C/...25-0372%202026-04-22%2022-00-23/OCC-2025-0372%202026-04-22%2022-00-23%20-%20TEST/OCC-2025-0372-0034.html[4/26/2026 11:30:44 PM]

RE: Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the
Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the
Currency
Docket ID: OCC-2025-0372
Date: March 28, 2026

My name is Brandon Smith. I am the founder of B2BTechnique, a financial technology company
developing compliance infrastructure software specifically for permitted payment stablecoin issuers
under the GENIUS Act. Our website is B2BTechnique.com.
I am submitting this comment to express support for Option A of proposed Section 15.11(c) and to
offer the perspective of a compliance technology developer building tools to help issuers meet the
requirements of this proposed rule.

SECTION 1 -- ON THE SAFE HARBOR STRUCTURE
The quantitative safe harbor in proposed Section 15.11(c)(2) -- requiring at least 10 percent daily
liquidity, at least 30 percent weekly liquidity, no more than 40 percent concentration at any single
eligible financial institution, and a weighted average maturity of no more than 20 days -- provides the
standardized, measurable targets that permitted payment stablecoin issuers need to build compliant
reserve management systems.
As a developer building software to automate this compliance workflow, I strongly support Option A
and urge the OCC to finalize it substantially as proposed. Standardized quantitative thresholds enable
issuers to implement automated monitoring and generate the audit trails that registered public
accounting firms will need to conduct monthly examinations under proposed Section 15.11(f)(1).
Option B, which relies on a principles-based approach without specific quantitative thresholds, would
create significant uncertainty for both issuers and the compliance technology providers building
systems to support them.

SECTION 2 -- ON STANDARDIZED MONTHLY DISCLOSURE FORMAT
I respectfully request that the OCC prescribe a standardized data format for the monthly reserve
composition report required under proposed Section 15.11(e).

A standardized format would reduce compliance costs for issuers, facilitate consistent examination by
registered public accounting firms, and improve the quality of public data available to market
participants and researchers. Without a standardized format, each issuer will independently develop its
own reporting structure. This creates unnecessary burden for examiners reviewing reports across
multiple issuers and reduces the comparability of public disclosures across the industry. A standardized
format would benefit issuers, examiners, accounting firms, and the public equally.

SECTION 3 -- ON THE WEIGHTED AVERAGE MATURITY DEFINITION
The proposed rule invites comment on whether the OCC should adopt the same weighted average
maturity definition used in SEC Rule 2a-7, including maturity assumptions for certain instruments
based on interest rate reset dates or demand repayment options rather than final maturity dates.
I support adopting a clear, express definition of weighted average maturity in the final rule, consistent
with the time remaining until repayment of principal as described in the proposed rule. The OCC's
stated expectation that maturity of reserve assets will be the time remaining until repayment of principal
is the correct approach for the limited range of permissible reserve assets under Section 15.11(b). A
clear, codified definition in the final rule will enable compliance software to calculate weighted average
maturity consistently across all issuers, reducing ambiguity for both issuers and examiners and
eliminating the risk of inconsistent interpretation across institutions.

SECTION 4 -- ON NOTIFICATION REQUIREMENTS FOR RESERVE SHORTFALLS
The proposed Section 15.11(g)(1) requires issuers to notify the OCC through its appropriate
supervisory office on any day their reserve asset amount falls below the required minimum. This is an
operationally critical provision.
I respectfully request that the OCC specify the exact notification format, submission method, and
timing window for this notification in the final rule. For example, the OCC should clarify whether
notification must occur before the close of business on the day the shortfall is identified, whether
notification must be submitted through a specific portal or supervisory channel, and what minimum
information must be included in the notification. Clear operational specifications will allow compliance
systems to automate this notification process and will reduce the risk of inadvertent procedural
violations by issuers who are otherwise in good faith attempting to remediate a reserve shortfall.

SECTION 5 -- ON THE EXAMINATION CYCLE FOR SMALLER ISSUERS

The proposed 18 to 36 month examination cycle for qualifying smaller issuers under proposed Section
15.14(d) -- applying to issuers with an outstanding issuance value of less than $1 billion or less than
$25 billion in total monthly trading volume -- is appropriate and proportionate.
This provision will encourage new entrants into the permitted payment stablecoin issuer market by
reducing the regulatory burden on smaller and less complex institutions that are in full compliance with
reserve and reporting requirements. I support this provision as proposed and encourage the OCC to
preserve it in the final rule.

CONCLUSION
The OCC's proposed implementing regulations for the GENIUS Act represent a thoughtful and
workable framework for the supervised issuance of payment stablecoins. The standardized, quantitative
approach of Option A under Section 15.11(c)(2) will enable issuers, examiners, accounting firms, and
compliance technology providers to build consistent, reliable systems around clear regulatory
expectations. I urge the OCC to finalize the rule substantially as proposed, with the additions of a
standardized monthly disclosure format, an express weighted average maturity definition, and clear
operational specifications for reserve shortfall notifications.
I appreciate the OCC's work in developing these implementing regulations and the opportunity to
participate in this public comment process.

Respectfully submitted,

Brandon Smith
Founder, B2BTechnique
B2BTechnique.com
[email protected] (Personal e-mail)
March 28, 2026