The National Cryptocurrency Association (NCA) and the Blockchain Association (BA) have each submitted recommendations to the U.S. Treasury regarding implementation of the GENIUS Act, according to letters reviewed by AMBCrypto. The NCA's letter, submitted on October 19, focuses on protecting existing stablecoin holders, while the BA warns that proposed rules could impose excessive compliance burdens on crypto companies.
NCA seeks transition protections for stablecoin holders
The NCA's primary concern is ensuring that ordinary Americans who already own stablecoins are not unfairly affected by regulatory changes. Specifically, the association argues that stablecoin holders should not lose access to their funds when a stablecoin becomes ineligible for issuance.
To address this, the NCA wants the U.S. Treasury to establish a transition period allowing existing holders to redeem, sell, or convert their stablecoins even after platforms have stopped offering them for new purchases. This would apply when temporary waivers expire, state certifications change, or when the July 18, 2028, deadline arrives.
The NCA also recommends publicly disclosing regulatory changes and deadlines to ensure consumers receive advance notice.
Recovery of stolen stablecoins and self-custody protections
Second, the NCA wants clear rules allowing stolen stablecoins to be recovered and returned to victims through lawful orders. It argues that issuers should be permitted to reissue stablecoins when legally required, without regulatory uncertainty obstructing recovery efforts.
Finally, the NCA urges the Treasury to establish clear protections and regulatory boundaries for self-custody wallets and peer-to-peer transfers. Overall, the association seeks stricter stablecoin regulation implemented without unfairly restricting existing holders' access to funds or undermining consumer protection.
Ripple's Chief Legal Officer Stuart Alderoty applauded the move in a post on X.
Blockchain Association warns of compliance burdens
The Blockchain Association has also submitted a comment letter to the U.S. Treasury on proposed GENIUS Act regulations. While supporting safer stablecoins, regulated issuers, and adequate reserves, the BA warns that the rules could impose excessive compliance burdens on crypto companies, exchanges, and DeFi platforms.
The BA wants regulators to distinguish between service providers so that no firms are unnecessarily regulated. Additionally, it wants platforms to rely on official government lists to verify foreign stablecoin issuers rather than conducting extensive investigations.
The association also opposes impractical requirements to identify or track anonymous users on decentralized networks. Lastly, it seeks clearer rules for algorithmic stablecoins, token bridges, and wrapped tokens.
Both submissions follow the U.S. Federal Reserve's recent proposal of two sets of rules under the GENIUS Act.
