As the U.S. Treasury considers implementing the GENIUS Act, signed into law in July, stablecoin issuer Circle is advocating for a level playing field between banks, non-banks, and stablecoin issuers.
In comments submitted on Tuesday as part of the Treasury Department’s notice of proposed rulemaking for GENIUS, Circle was one of a number of crypto companies to comment on how the U.S. government should implement legislation establishing a framework for stablecoin payments.
The company reiterated many of the principles that the bill’s supporters have advocated, such as ensuring stablecoins are “fully backed by cash and high-quality liquid assets,” but also called on the government to set clear requirements for enforcement and consequences for non-compliance.
“Banks, non-banks, domestic and foreign issuers should follow the same rules to protect consumers from taking risks from any regulatory shortcuts,” the Circle said in a notice on Thursday. “Clear requirements for accessing U.S. markets and joint oversight with trusted foreign regimes foster competition while preventing offshore arbitrage.”

sauce: circle
The Circle’s recommendations were made as part of the second round of public comment on the implementation of GENIUS. US President Donald Trump signed the stablecoin bill into law in July, but it would go into effect 18 months after enactment, or 120 days after regulators approve regulations related to implementation.
Related: Bank of England promises to align with US on stablecoin regulation
Coinbase also commented on the GENIUS Act and submitted a recommendation to the Treasury Department asking the Treasury Department to limit the ban on interest payments on stablecoins to issuers only, but allow them for crypto exchanges. The comments came after pushback from banking groups urging policymakers to address interest-bearing stablecoins in the bill.
Congress still awaits action on market structure
Although GENIUS was signed into law nearly three months ago, the Digital Asset Market Structure Act, which passed the U.S. House of Representatives, has seen little movement in the Senate as Congress continues to adjourn for a month and the government shutdown, now in its 37th day.
Senators are reportedly holding bipartisan discussions on the market structure bill, but as of Thursday morning, neither the Agriculture nor Banking committees had released any additional drafts or updates. Republican leaders said in August that they expected the bill to be signed into law by 2026.
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