Ripple Chief Legal Officer Stuart Alderoty has asked the US Treasury to build holder protections into the stablecoin rules being drafted under the GENIUS Act, arguing that a regulatory failure at an issuing company should not leave token holders unable to reach their money.
Alderoty submitted formal comments to the Treasury on October 19, 2026, the final day of the public comment period on the law. He filed on behalf of the National Cryptocurrency Association (NCA) rather than solely as a Ripple executive, a structure that signals an attempt to represent a broader set of users rather than one company's business interests.
What the filing asked for
The GENIUS Act, passed in 2025, establishes a framework for payment stablecoins — digital tokens designed to hold a steady value, typically pegged to a currency such as the dollar. Its central feature is a 100% reserve requirement, which Alderoty's comments supported.
Reserves were only part of the submission. Alderoty focused on what happens to ordinary holders when something goes wrong with the company that issued their coins. The proposed safeguards include:
- Safe-harbor redemption periods, giving holders time to cash out if an issuer loses its authorization or runs into compliance trouble.
- Recovery pathways for stolen assets, so theft victims have a route to recovering funds.
- Protection for self-custody and peer-to-peer transfers, preserving the ability to hold coins directly and send them to others.
The common thread, as framed in the filing, is that a regulatory problem at the issuer level should not lock the person holding the token out of their money.
Software providers versus custodians
Alderoty also drew a distinction between software providers and custodial intermediaries. A custodian actually holds a user's assets, the way a bank holds deposits, while a software provider such as a wallet app may only supply the tools to manage assets the user controls.
Keeping that line clear, he argued, helps consumers retain control of their digital assets during regulatory transitions.
The timeline ahead
The new stablecoin rules are expected to begin taking effect on January 18, 2027. With the comment window now closed, the Treasury will work through the submissions and settle the details that turn the statute's broad language into specific obligations.
For holders, the most practical element of the filing is the safe-harbor proposal, since a stablecoin's usefulness depends on the ability to redeem it — an ability most tested by a sudden issuer shutdown. The self-custody and peer-to-peer provisions touch a long-running tension in crypto policy, with regulators generally preferring activity to flow through identifiable intermediaries while many users value holding and moving assets themselves.
For issuers, the full-reserve mandate remains the headline obligation. Full backing raises the cost of running a stablecoin, but it also gives compliant issuers a clear explanation to users and institutions about why their token holds its value.
