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The comment letter submitted to the U.S. Treasury by the National Cryptocurrency Association (NCA) on the Section 3 rules of the GENIUS Act (Docket TREAS-DO-2026-0496) closes the period of uncertainty surrounding stablecoin regulation
The document, signed by NCA President and Ripple Chief Legal Officer Stuart Alderoty, states that the industry accepts the requirement for one-hundred-percent reserves but puts forward a practical framework for protecting retail holders, so that Americans do not end up "stranded holding stablecoins if regulations change."
The first requirement eliminates the risk of a sudden change in issuers' legal status. Missing the July 18, 2028 deadline or the revocation of a company's license must not result in the automatic blocking of citizens' funds. Alderoty calls for a safe-harbor mechanism: a temporary window within which users can redeem, sell, or convert their coins without loss, and exchanges can provide technical support without the risk of being accused of illegal trading activity
The second priority is the creation of legal mechanisms for the return of stolen assets. The NCA proposes to establish that reissuing a payment stablecoin to replace one that was stolen or mistakenly transferred, by court decision, is fully legal and falls under the "except as required by a lawful order" exception
The freezing procedure itself is proposed to be synchronized with FinCEN standards, obliging issuers to promptly notify affected users
The third set of rules draws a firm line between custodial services and software developers. Providers of non-custodial wallets and interfaces that merely display a balance and do not control access keys cannot be recognized as intermediaries or sellers
According to the NCA's position, any direct P2P transfers, transactions between individuals' own accounts, and operations within personal wallets must remain strictly outside the agency's restrictions, guaranteeing the right to "self-custody plus peer-to-peer transfers."
The GENIUS Act established the framework. Now, Treasury’s rules must ensure that Americans are not stranded holding stablecoins if regulations change, have pathways to recover stolen funds, and can self-custody if they choose
The filing of this document moves the dialogue between the crypto industry and U.S. regulators onto a pragmatic track. By outlining the boundaries of a technological compromise, big business has effectively placed responsibility for the stability of the retail market on the Treasury Department, which must now decide how strict the final rules will be
