Anchorage Digital Policy Library: Comment Letters & Perspectives

GENIUS Act Implementation

The GENIUS Act is the new federal law governing stablecoins. Regulators are now writing the detailed rules that will implement it, and we're commenting on each one as it comes up.

Early stablecoin implementation priorities (Treasury) — Submitted November 4, 2025 Before any rules were proposed, Treasury asked the public how it should implement the GENIUS Act. As the first federally regulated stablecoin issuer, Anchorage Digital Bank, N.A. answered with four priorities. Issuers should have room to manage their reserve mix under regulators’ supervision. Issuers can’t pay yield to stablecoin holders, but they should still be able to use reserve income for ordinary business costs like custody and revenue sharing with partners, which the white-label issuance model depends on. Reserves held outside bank deposits should sit with qualified custodians that have clear bankruptcy protections. State and foreign regimes should be held to a standard “not less stringent” than the federal one. 🔗 Read our comment letter

Customer identification rules (FinCEN) — Submitted August 21, 2026 Regulators proposed rules requiring stablecoin issuers to verify who their customers are, similar to standard bank "know your customer" requirements. Anchorage Digital Bank, N.A. weighed in to help ensure these rules work in practice for how stablecoins operate. 🔗 Read our comment letter

Anti-money laundering & sanctions rules (Treasury/FinCEN/OFAC) — Submitted June 9, 2026 This rule sets out how stablecoin issuers should screen for illicit activity and enforce sanctions. We support the core approach. Regulators smartly focused monitoring obligations on the primary issuance relationship rather than trying to track every downstream trade and asked for a few clarifications so issuers aren't held responsible for things outside their control, like anonymous secondary-market transfers. 🔗 Read our comment letter

Stablecoin issuance rules (OCC) — Submitted May 1, 2026 As the first federally regulated stablecoin issuer, we responded to the OCC's core rulebook for how banks like ours issue stablecoins. Our letter explains how holding reserve assets in separate legal trusts already delivers the safeguards regulators want, and pushes back on rigid one-size-fits-all reserve rules and an automatic seven-day redemption freeze that could actually trigger the kind of run it's meant to prevent.  🔗 Read our comment letter

Who can issue and sell stablecoins in the U.S. (Treasury) — Submitted October 19, 2026 Treasury proposed rules spelling out what it means to issue, offer, or sell a stablecoin in the United States. We support the core approach, including a narrow definition of “issuer,” and asked Treasury to close a few gaps so that technology and brand partners aren’t treated like issuers, custodians aren’t treated like sellers just for holding assets, and following EU redemption rules doesn’t put a company at odds with U.S. law. We also asked for a clear process and timeline for deciding which foreign rulebooks count as comparable. 🔗 Read our comment letter

Getting Fair Access to the Federal Reserve

National trust banks like Anchorage Digital Bank have historically had a harder path to basic Federal Reserve services than banks with federally insured deposits — even though we're regulated by the same federal agency, under the same laws, and do not lend. Granting national trust banks full access to a fed master account enhances financial stability, levels the playing field, and helps move the financial system toward digital assets and blockchains.. 

A National Trust Bank Is a National Bank — Submitted July 29, 2026, Federal Reserve The Fed proposed a stripped-down "Payment Account" for banks like ours instead of full account access. We support modernizing access, but pointed out that an account with no ability to move money through the most useful payment rails, tight balance caps, and no interest isn't a real substitute for the account other national banks have had for a century. 🔗 Read our comment letter

Companion letter on interest for Payment Accounts — Submitted July 2026, Federal Reserve A follow-up letter reinforcing many of the points we made in the first letter above to the Federal Reserve.  🔗 Read our comment letter

Executive Perspectives

A National Trust Bank Charter Is Not an End Run Around Regulation By Nathan McCauley, Co-Founder & CEO, American Banker, October 26, 2026 Responding to the Independent Community Bankers of America’s lawsuit against the OCC over national trust bank charters, McCauley argues that a national trust bank is a national bank, held to the same supervision, examination, capital, and anti-money laundering requirements as any other. Deposit insurance is the wrong yardstick, he writes, because a trust bank provides fully reserved, segregated custody rather than lending out deposits. Bringing new technology inside the federal regulatory perimeter makes the financial system stronger, and community banks are vital but shouldn’t get a veto over competition.

GENIUS Worked. Now Congress Is Stalling on the Sequel — But China's Not Waiting By Nathan McCauley, Co-Founder & CEO — Washington Examiner, July 18, 2026 One year after GENIUS passed, McCauley argues Congress needs to finish the job with the CLARITY Act and  extend the same clear rules to exchanges, broker-dealers, and custody — or risk falling behind China and Russia.

America Doesn't Need a Second-Class Payments System By Rachel Anderika, Head of Global Operations — CoinDesk, August 12, 2026 Drawing on her experience as a former OCC bank examiner, Anderika makes the case that the Fed's "skinny" account proposal doesn't solve the real problem: banks like ADB still depend on other banks just to move money.

The Dollar's Next Battlefield Isn't a Country. It's Code. By Dustin Palmer, Bank Secrecy Act Officer — The Cipher Brief, August 13, 2026 Palmer argues that as China and Russia build their own state-backed digital currencies, bringing dollar stablecoin activity onshore, under U.S. supervision strengthens America's ability to track and freeze illicit money, not weaken it.

Stablecoins Can Only Assure Dollar Dominance If the Rules Make Sense By Rachel Anderika, Head of Global Operations, American Banker, June 24, 2026 Drawing on her decade as an OCC bank examiner, Anderika backs the agency’s proposed GENIUS Act rules as rigorous but warns that two design choices could cause the crises they’re meant to prevent. The automatic seven-day redemption gate, she writes, is “a countdown clock, not a safeguard,” and the insured-deposit reserve requirement repeats the exposure that cost USDC its peg in 2023. She urges principles-based rules that let issuers show how they meet clear outcomes.

Anchorage Digital is the proven infrastructure layer for modern financial markets, giving institutions a single platform to participate in digital assets — including prime services, tokenization, stablecoins, and the governance framework for agentic finance. Home to Anchorage Digital Bank N.A., America's first federally regulated digital asset bank, Anchorage Digital also serves institutions through Anchorage Digital Singapore, Anchorage Digital NY, and self-custody wallet Porto by Anchorage Digital. Learn more at anchorage.com.

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