The Blockchain Association Files 26 Pages of "Hold My Beer, Congress Meant This" 💼

The Blockchain Association filed a 26-page comment letter on October 19, 2026, urging the U.S. Treasury Department to tighten its proposed rules implementing the GENIUS Act before the framework's January 18, 2027 effective date. The trade group said Treasury's draft must hew closer to the statute Congress passed, warning that loose definitions could pull in unintended actors across the $302 billion stablecoin market.

The letter, addressed to senior Treasury staff, lands at the close of a comment period that drew 123 submissions on the proposed rule governing payment stablecoin issuance, offering and sale. While the Blockchain Association backs Treasury's stated aim of fostering safe, reserve-backed stablecoins from regulated entities, it flagged three areas it says need sharpening before finalization.

First, the association argued for a narrower definition of "digital asset service provider," or DASP, to avoid sweeping in non-custodial DeFi infrastructure and other parties that lack control over user funds. Third, it pushed for limiting "knowing participation" liability so the rule does not capture downstream actors who do not knowingly facilitate unlawful conduct. And second, it said Treasury should rely on public prohibition lists rather than open-ended conduct tests when restricting foreign issuers of stablecoins.

The filing reflects the Blockchain Association's broader effort to ensure that stablecoin oversight in the United States, particularly as it touches decentralized finance and cross-border payment stablecoin issuers, does not extend beyond what the GENIUS Act statute authorizes. Treasury has not publicly responded to the letter, and the next step in the process is the issuance of a final rule ahead of the January 18, 2027 effective date, with clarity on these three pillars now widely seen as key to preserving liquidity and legal certainty across compliant stablecoin issuers operating in the U.S. market.