Circle Urges “Same Activity, Same Rules” For GENIUS Act Stablecoins

Circle submitted a comment letter to the U.S. Department of the Treasury, responding to the Advance Notice of Proposed Rulemaking on the GENIUS Act.

The filing outlines a national framework for payment stablecoins and describes how uniform requirements could support users, issuers, and intermediaries across U.S. markets.

The letter presents its recommendations within a single regime that accommodates both permitted U.S. issuers and qualifying foreign issuers, while ensuring consumer funds are protected through clear reserve, redemption, and disclosure standards established in rules rather than marketing claims.

Policy Principles And Supervision

Circle proposes that payment stablecoins be fully backed with cash and high-quality liquid assets, kept separate from company funds, and redeemable at par on demand, with independent monthly checks and plain language reports that allow users and supervisors to verify backing.

The company links these requirements to a level playing field for bank and nonbank issuers under a common prudential baseline, and to a standalone issuer structure with the staffing and controls needed to meet obligations in the Act.

The letter calls for a reciprocal path for foreign regimes that match GENIUS standards and that maintain ongoing supervision. It adds that determinations should be published so market participants can understand which cross-border issuers qualify.

Circle also supports predictable penalties and safe harbor protections for good faith compliance with lawful orders, together with tested wind-down plans that return customer funds quickly and fairly across borders.

“Same activity, same rules—no loopholes. If a digital token walks and talks like a dollar, it should have the same obligations as a payment stablecoin under the Act,” the letter reads. “Labels or marketing shouldn’t let anyone dodge safeguards.”

Market Use, Global Reach, And Accounting Treatment

Circle asks Treasury to clarify how permitted U.S. issuers can operate globally so that conversion between dollars and tokens remains practical for businesses and platforms that settle activity across time zones.

The letter ties that clarification to liquidity management and to interoperability with regulated financial infrastructure so that payment flows do not fragment when they move between banks, brokers, and exchanges.

The submission recommends that permitted payment stablecoins be treated as cash and cash equivalents for accounting and tax purposes, which would align financial reporting with the fully reserved model and reduce ambiguity for treasurers and auditors.

It also urges clear guidance that applies GENIUS obligations to any token designed to maintain a stable value in payments, including products that deny redemption but otherwise function like compliant payment stablecoins, so that consumer protection and market integrity do not depend on labels.

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