Public Comments

Status: Original and derived artifacts are available for this document.

Download: pdf

012345ÿ712847749

ÿÿÿÿ
!ÿ"#$%&ÿÿ
7'(')ÿ*+,-.
0 '!ÿ/0ÿÿ
12(345ÿ 6ÿ7*&8,,/89:0+
5 ;;4'ÿ<)ÿ/0ÿ=ÿ
ÿÿ>/,-ÿ?*77-@,+ÿ/$-ÿ/??-#,-.
7)A;4ÿ1BCÿ"D

< 3'ÿEFF88G
D7#&-7-@,%@Hÿ,:-ÿIJ%.%@Hÿ/@.ÿK+,/L&%+:%@HÿM/,%*@/&ÿD@@*N/,%*@ÿ9*$ÿOPQPÿQ,/L&-?*%@+ÿ"?,ÿ9*$ÿ,:-ÿD++J/@?*9ÿQ,/L&-?*%@+ÿL0ÿK@,%,%-+ÿQJLR-?,ÿ,*ÿ,:-ÿSJ$%+.%?,%*@ÿ*9ÿ,:-ÿE99%?-ÿ*9ÿ,:-ÿF*7#,$*&&-$ÿ*9ÿ,:-ÿFJ$$-@?0
5 ;;4'ÿ94ÿEFF88G8=
IJ%.%@Hÿ/@.ÿK+,/L&%+:%@HÿM/,%*@/&ÿD@@*N/,%*@ÿ9*$ÿOPQPÿQ,/L&-?*%@+ÿ"?,ÿ9*$ÿ,:-ÿD++J/@?-ÿ*9ÿQ,/L&-?*%@+ÿL0
K@,%,%-+ÿQJLR-?,ÿ,*ÿ,:-ÿSJ$%+.%?,%*@ÿ*9ÿ,:-ÿE99%?-ÿ*9ÿ,:-ÿF*7#,$*&&-$ÿ*9ÿ,:-ÿFJ$$-@?0
< );4'ÿEFF88G8
I&*L/&ÿ>-H/&ÿK@,%,0ÿD.-@,%9%-$ÿT*J@./,%*@

7)A;''2ÿ442;('4

!!2 ÿO@%,-.ÿQ,/,-+ÿ
U;(Vÿ#-,-$PW/$7+XH&-%9P*$H
7)A;''2YÿC24'('ÿ"&-Z/@.$-ÿ[-?:
925(4\('4ÿI&*L/&ÿ>-H/&ÿK@,%,0ÿD.-@,%9%-$ÿT*J@./,%*@ÿ]I>KDT^

_42(Vÿ5 ;;4'

Q--ÿ/,,/?:-.ÿ9%&-]+^ÿ,:%+ÿN-$+%*@ÿ$-#&/?-+ÿ,:-ÿ#$-N%*J+ÿ+JL7%++%*@ÿ9$*7ÿI>KDTÿW%,:ÿ,:-ÿ9*&&*W%@Hÿ9%&@/7-ÿ88`ab-+#*@+-8I>KDTÿ"7-$%?/+aEFFaIKMDOQaQ,/L&-?*%@+a9%@/&P#.9

''(c;4'

I&*L/&ÿ>-H/&ÿK@,%,0ÿD.-@,%9%-$ÿT*J@./,%*@ÿ]I>KDT^

GLEIF Americas
a NJ Nonprofit Corporation
2500 Plaza 5
25th floor
Harborside Financial Center
Jersey City, NJ 07311

Submission to the Office of the Comptroller of the Currency
RE: Proposed Rule, 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
Submitted by: Global Legal Entity Identifier Foundation (GLEIF)
Date: April 28th, 2026
Dear Comptroller of the Currency (OCC),
The Global Legal Entity Identifier Foundation (GLEIF) appreciates the opportunity to respond to the
OCC’s notice of proposed rulemaking. As the not-for-profit organization tasked with operating the
Global Legal Entity Identifier System (GLEIS), GLEIF proposes the integration of the Legal Entity
Identifier (LEI) and its cryptographically verifiable counterpart, the verifiable LEI (vLEI), to promote
transparency, enhance fraud detection, and support innovation in stablecoin markets.
First, some background on GLEIF:
Established by the Financial Stability Board (FSB) in June 2014 under the mission of improving
financial stability and transparency due to the aftermath of the financial crisis, GLEIF is tasked to
support the implementation and use of the LEI (Legal Entity Identifier, ISO 17442). Even though the
primary and initial usage and adoption of the LEI predominantly was in financial markets and
financial instruments, the LEI is use-case agnostic and therefore has been embraced by different
industry sectors and regulators since its introduction by the Regulatory Oversight Committee (ROC),
in which the OCC is a member, as are the Board of Governors of the Federal Reserve System (Board),
Consumer Financial Protection Bureau (CFPB), Commodities Futures Trading Commission (CFTC),
Department of Treasury (DoT), and the Securities Exchange Commission (SEC) are members.
The LEI and the verifiable LEI (vLEI):
The “Legal Entity Identifier” or “LEI” is a 20-character, alpha-numeric code based on the ISO 174421:2020 standard developed by the International Organization for Standardization (ISO). The LEI
uniquely and unambiguously identifies a legal entity, and which meets the requirements of section
124(c)(1) of the Financial Data Transparency Act (FDTA). The LEI is nonproprietary, and the LEI data is
made publicly available under an open license, free of charge to any interested user. The LEI
connects to key reference information that enables clear and unique identification of legal entities
participating in financial transactions including their ownership structure.
In October of 2024, the ISO 17442 standard was expanded to specify how LEIs can be embedded in
digital credentials. The vLEI is a digital credential that makes an LEI instantly and cryptographically
verifiable when presented in digital form, enabling digital interactions that utilize the vLEI to have a
high level of assurance about the identity of the actors and the organizations they represent.
The vLEI addresses critical needs to tackle emerging identity-based risks, offering a secure, verifiable
approach to organizational identity and organizational credentials, namely the permissioning and
Page 1 of 6

GLEIF Americas
a NJ Nonprofit Corporation
2500 Plaza 5
25th floor
Harborside Financial Center
Jersey City, NJ 07311

authentication of organizational identity and the digital signing and submission of official
documentation (such as regulatory filings, reports, data submissions), including the signing of the
content therein. vLEIs are digital credentials that leverage the LEI to indicate the identity of a legal
entity, enabling the cryptographic verification of the identity of the organization to its LEI and allows
further verification that persons accessing a portal or system for filings, reports or data represent
that organization. Further digital signing of filings, reports or data prevents the tampering of the
filing, report or data from the point that it is signed by the organization.
Request for Comment:
Question 131: Has the OCC identified in the proposed form the appropriate data fields and
categories of information to collect from a permitted payment stablecoin issuer on a weekly basis
to understand the operations and risks unique to its business model? If not, are there data fields
that the OCC should not request on a weekly basis and are there any additional data fields beyond
those proposed that the OCC should collect on a weekly basis from a permitted payment stablecoin
issuer to better assist in understanding the operations and risks unique to its business model?
GLEIF recommends that to facilitate machine-readable reports, trust, and validation, the Permitted
Payment Stablecoin Issuer (PPSI) should submit their LEI with their weekly reports. This aligns with
best practices for identifying the filing entity and its parent companies. This aligns more broadly with
the response to Question 167 below.
GLEIF also recommends that the OCC require PPSIs to report the LEI(s) of any entity(s) custodying
their reserve assets on a weekly basis. Given that reserve asset custodians are subject to specific
eligibility requirements under Section 10 of the GENIUS Act, weekly LEI disclosure of those
custodians would allow the OCC to efficiently monitor changes in custody arrangements, assess
concentration risk, and verify that custodians remain eligible regulated financial institutions, all in a
machine-readable format consistent with best practices.
Question 167: Should the OCC explicitly provide in regulation that the application process under
proposed § 15.30 supersedes all other filing requirements in OCC regulations related to issuance of
stablecoins?
GLEIF recommends that the requirements should specify that applications of PPSI’s should each
report with an LEI. The OCC's focus on identifying, regulating, and tracking newly licensed
subsidiaries implies the necessity of robust identification, such as an LEI, to manage the "primary
Federal payment stablecoin regulator" responsibilities for PPSIs.
More specifically, the LEI should be included in the application and registration process for the
identification of national banks and their subsidiaries, Federal savings associations and their
subsidiaries, Federal branches and their subsidiaries, foreign payment stablecoin issuers, nonbank
entities that seek to be or are approved as Federal qualified payment stablecoin issuers, and State
qualified payment stablecoin issuers for whom the OCC has regulatory or enforcement authority
pursuant to the GENIUS Act.

Page 2 of 6

GLEIF Americas
a NJ Nonprofit Corporation
2500 Plaza 5
25th floor
Harborside Financial Center
Jersey City, NJ 07311

Notably, Section 5(c)(5) of the GENIUS Act (12 U.S.C. Section 5904(c)(5)) grants the OCC authority to
establish “any other factors” that are “necessary to ensure the safety and soundness” of the
permitted payment stablecoin issuer. Use of the LEI would ensure the unique identification of the
permitted payment stablecoin issuer. It is a minimal, globally standardized disclosure requirement
that directly supports the OCC’s ability to identify, monitor, and supervise permitted payment
stablecoin issuers and assess their place within broader financial networks. It is not a substantive
operational requirement and does not impose conditions beyond those an operationally ready
financial entity would already satisfy or could satisfy at de minimis cost.
Including the LEI in the Interagency Biographical and Financial Report for PPSIs would increase
transparency, facilitate better monitoring of interconnectedness between stablecoin issuers and
traditional finance, and align with the GENIUS Act’s goal of high-standard, bank-like reporting.
Furthermore, as other primary federal payment stablecoin regulators contemplate the issuance of
proposed rules for entities under their supervision to become PPSIs, namely the National Credit
Union Administration, the Board of Governors of the Federal Reserve System, and the Federal
Deposit Insurance Corporation, the LEI can act a linchpin, which will enable efficient sharing of
information across regulators.
Question 171: Should the OCC require different or additional information to be reported by foreign
payment stablecoin issuers? If so, what additional information should the OCC require? How
frequently should the OCC require such information? Should any additional information be made
public? Should the OCC expressly require foreign payment stablecoin issuers to provide the same
reports, publish the same reports, and make and publish the same certifications as permitted
payment stablecoin issuers? If not, what modifications to the reporting, publication, and
certification requirements would be appropriate for foreign payment stablecoin issuers?
Similar to Question 167, GLEIF suggests that the OCC also leverage the LEI for the identification of
Foreign Payment Stablecoin Issuers (FPSIs). The GENIUS Act brings core elements of the stablecoin
ecosystem into a formal financial regulatory framework; this evolution necessitates robust
identification and reporting systems like LEIs for compliance.
The entity identification challenges posed by foreign payment stablecoin issuers are structurally
more acute than those posed by domestic applicants. Foreign issuers may be organized under
unfamiliar legal frameworks, operate under trade names that differ from their registered legal
names, and sit within complex multi-jurisdictional corporate structures. The proposed Section 15.32
registration process does not, on its face, require the submission of a standardized, globally
interoperable entity identifier. Without such an identifier, the OCC’s ability to verify the identity of a
foreign registrant, assess its corporate family relationships, and coordinate with the issuer’s home
regulator will depend on ad hoc, manual reconciliation of entity data across jurisdictions, a process
that is slow, error-prone, and inherently less reliable than a common identifier standard.
Specifically, LEIs provide a crucial mechanism for BSA/AML reporting and tracking, facilitating the
detailed oversight mandated by the Act. The LEI already plays an important role in international
efforts to regulate digital asset market structure and address illicit finance and money laundering
issues. Aligning these requirements with existing internationally recognized standards will not only

Page 3 of 6

GLEIF Americas
a NJ Nonprofit Corporation
2500 Plaza 5
25th floor
Harborside Financial Center
Jersey City, NJ 07311

promote interoperability across jurisdictions but also reduce the relative compliance burden for
digital asset market participants. To that end, GLEIF supports leveraging LEI and vLEI to complement
or comply with:
•

The Bank Secrecy Act and sanctions screening by enabling automated entity resolution and
wallet screening based on verified credentials.

•

FATF Recommendation 16 (“Travel Rule”) to identify originators and beneficiaries of digital
asset transfers.
o

The LEI is explicitly referenced within the interpretive note to Recommendation 16.
The text states that where the originator or beneficiary of a cross-border or domestic
payment or value transfer is a legal person, the LEI may accompany the transaction.
This reinforces the LEI’s role in supporting transparency and traceability in global
payment systems.

o

The Financial Crimes Enforcement Network (FinCEN), Department of Treasury,
enforces the U.S. version of the Travel Rule, requiring financial institutions, including
stablecoin issuers, to share originator and beneficiary information for transactions
above a threshold.

There are several existing financial regulations in major foreign markets, which mandate regulated
entities to include an LEI in a variety of different registration and regulatory filings. For example, the
European Union’s Markets in Crypto-Assets (MiCA) regulation, adopted in May 2023, requires the
submission of an identifier, specifically the LEI, as part of the registration for most digital asset
market participants in both the statute and implementing regulation. This carries benefits for
international information sharing, particularly for managing risks such as money laundering, terrorist
financing, and other forms of illicit finance.
Under MiCA, digital asset market participants seeking to operate in the EU must obtain an LEI as part
of the registration requirements of the regulation. Specifically, this includes U.S. based entities that
create and issue digital assets as well as companies that provide digital asset trading and other
services.
Entities issuing certain types of crypto-assets must include their LEI when registering required
disclosures (e.g., in the EU register of crypto-asset white papers and issuers). This ensures that
issuers of tokens are uniquely identifiable in public records, enhancing transparency for investors
reviewing a token’s documentation. Similarly, firms providing crypto-asset services (exchanges,
custodians, etc.) are required to apply for authorization in their home EU Member State. As a
prerequisite to this application, an LEI must be obtained and provided to the regulator. In practice,
this means no crypto-asset service providers (CASPs) can be licensed under MiCA without a valid LEI,
embedding the LEI into the operational onboarding of every service provider.
These requirements are explicitly codified in MiCA’s provisions (e.g., Article 18, Article 62, and Article
109), obligating legal entities to provide an LEI during authorization and in ongoing compliance
filings. By mandating the LEI, MiCA aligns with international standards, such as the FATF Travel Rule
guidelines, promoting consistent and interoperable legal entity identification in transactions.

Page 4 of 6

GLEIF Americas
a NJ Nonprofit Corporation
2500 Plaza 5
25th floor
Harborside Financial Center
Jersey City, NJ 07311

More recently, the Financial Conduct Authority proposed CP26/4: Application of FCA Handbook for
regulated cryptoasset activities – part 21, in which the proposed rules include the LEI for the
identification of firms conducting certain cryptoasset activities.
Background on the Inclusion of the LEI in FDTA Joint Proposed Rules:
GLEIF also wants to provide an update on the Financial Data Transparency Act, which was enacted as
Title LVIII of the FY23 NDAA (P.L. 117–263).The Act passed the House on suspension earlier that
Congress (H.R.2989, 117) and has remained a bipartisan effort through the implementation process
to date. The U.S. financial regulators proposed joint rules to implement the statute in August 2024.
Eight of the regulators were required by statute to participate, and the CFTC opted voluntarily to
participate. The FDTA as enacted amends subtitle A of the Financial Stability Act of 2010 (Financial
Stability Act) by adding a new section 124, which directs the Agencies jointly to issue regulations
establishing data standards for (1) certain collections of information reported to each Agency by
financial entities under the jurisdiction of the Agency, and (2) the data collected from the Agencies
on behalf of the Financial Stability Oversight Council (FSOC). The term “data standard” is defined by
the statute as a standard that specifies rules by which data is described and recorded, and its core is
a legal entity identifier.
The statute outlines specific criteria in the language below that an identifier must meet to be used
for the data standard:
‘‘(c) DATA STANDARDS.—
‘‘(1) COMMON IDENTIFIERS; QUALITY.—The data standards established in the final rules
promulgated under subsection (b)(2) shall—
‘‘(A) include common identifiers for collections of information reported to covered agencies or
collected on behalf of the Council, which shall include a common nonproprietary legal entity
identifier that is available under an open license for all entities required to report to covered
agencies; and
‘‘(B) to the extent practicable—
‘‘(i) render data fully searchable and machine-readable;
‘‘(ii) enable high quality data through schemas, with accompanying metadata documented in
machine readable taxonomy or ontology models, which clearly define the semantic meaning of the
data, as defined by the underlying regulatory information collection requirements;
‘‘(iii) ensure that a data element or data asset that exists to satisfy an underlying regulatory
information collection requirement be consistently identified as such in associated machine-readable
metadata;
‘‘(iv) be nonproprietary or made available under an open license;
‘‘(v) incorporate standards developed and maintained by voluntary consensus standards bodies; and

1

https://www.fca.org.uk/publications/consultation-papers/cp26-4-application-handbook-regulatedcryptoasset-activities-II

Page 5 of 6

GLEIF Americas
a NJ Nonprofit Corporation
2500 Plaza 5
25th floor
Harborside Financial Center
Jersey City, NJ 07311

‘‘(vi) use, be consistent with, and implement applicable accounting and reporting principles.”
In section II(B) of the August 2024 proposed joint rule, the agencies propose to establish the
International Organization for Standardization (ISO) 17442-1:2020, Financial Services—Legal Entity
Identifier (LEI) as the legal entity identifier joint standard required by the statute. The agencies have
enumerated the reasons why the LEI fits the criteria outlined in the statute and why other identifiers
were considered and not included in the rule. As the OCC and future regulators continue to
promulgate stablecoin regulation, GLEIF encourages regulators to incorporate statutory language on
the use of identifiers to promote efficiency and transparency for both federal regulators and the
entities covered by these frameworks. This alignment with the FDTA would be beneficial because the
FDTA statute mandates two sets of rulemakings: first, the joint rulemaking for the financial agencies
to establish the data standard/identifier (released August 2024), and second, a series of individual
agency-specific rulemakings that apply the final data standard to their information collections. With
the OCC as party to the August 2024 rule, incorporating references to the LEI/vLEI or the FDTA’s
common identifier/data standard language into the GENIUS Act and future market structure
legislation will give both agencies direction on the intersection between the legislation and the FDTA.
This would also give digital asset market participants clarity from the start on whether they may be
expected to provide the LEI as part of their registration.
GLEIF appreciates the opportunity to provide feedback on this proposal and remains at OCC’s
disposal to further discuss and support your work. Do not hesitate to engage us in your discussions
and questions related to standards.
Submitted by:
Alexandre Kech, GLEIF CEO
[email protected]

Page 6 of 6