Circle has submitted a comment letter to the U.S. Securities and Exchange Commission (SEC) seeking clarification on the treatment of qualifying payment stablecoins under the agency’s proposed Regulation Crypto Assets framework.
Key requests in the letter
The October 20 comment letter, summarized by Circle on October 28, asks the SEC to:
- Coordinate the proposed Regulation Crypto Assets with the GENIUS Act and clarify how qualifying payment stablecoins can be used as consideration and settlement assets.
- Provide cash treatment for qualifying stablecoins under the proposed Rule 302(b).
- Reduce the broker‑dealer haircut for qualifying stablecoins from the proposed 2% to zero, subject to appropriate safeguards.
Implications of a regulatory haircut
A regulatory haircut is a deduction applied when an asset is recognized for certain financial calculations. Changing the haircut rate can affect a firm’s balance‑sheet efficiency, even if the underlying asset remains unchanged.
Technical maintenance considerations
Circle also seeks guidance on how ongoing technical services for a functional blockchain network should be treated under the rules, distinguishing routine maintenance from the original investment proposition.
Next steps
The letter reflects Circle’s position as an interested market participant. It does not indicate that the SEC has adopted the requested treatment. Future SEC actions or revisions to the proposal will determine the final regulatory approach.
