PTG Responds to OCC GENIUS Act Implementation Proposal
May 8, 2026
Today, PTG submitted a comment letter to the Office of the Comptroller of the Currency (OCC) in response to the OCC’s proposed rule implementing the GENIUS Act for payment stablecoin issuers. While PTG supports the OCC’s broader goal of creating regulatory clarity for stablecoins, the letter urges the agency to reconsider proposed Rule 15.12(c), which would require a mandatory seven-day redemption delay whenever redemptions exceed 10 percent of outstanding issuance value in a 24-hour period. PTG argues that, rather than promoting financial stability, this automatic delay could undermine confidence in stablecoins and increase the risk of market disruption.
The letter explains that the possibility of a seven-day lockup could encourage sophisticated market participants to redeem early, potentially accelerating redemption pressure and making instability more likely. PTG also warns that the delay would impair the arbitrage process that helps stablecoins maintain their peg, because firms would be unwilling to tie up capital for seven days to redeem discounted tokens at par. In PTG’s view, this would weaken a key market-stabilizing mechanism and could intensify panic selling during periods of stress.
Finally, PTG argues that the proposed redemption delay would reduce the usefulness of stablecoins as tokenized collateral in broader financial markets. Because clearinghouses and other participants would have to account for the risk that stablecoins could become temporarily illiquid, they may apply larger haircuts or decline to accept them as collateral at all. PTG suggests the OCC consider alternatives, such as requiring issuers to self-certify their ability to meet redemptions or focusing more on reserve requirements, and concludes by respectfully requesting that the OCC reconsider Rule 15.12(c).