Circle has submitted a comment letter to the U.S. SEC on its proposed Regulation Crypto Assets, recommending that compliant payment stablecoins be classified as "cash" under Rule 302(b) and aligned with the GENIUS Act. The filing calls for zero-dollar-denominated accounting treatment and customer reserve provisions for stablecoins meeting GENIUS Act standards. Circle also proposed reducing the current 2% haircut applied to broker-dealers holding such stablecoins to zero, provided objective safeguards are in place. Additionally, the company requested SEC clarity that post-launch technical services—including maintaining known validator sets—should not constitute "critical managerial effort," and urged establishment of a safe harbor for technology roadmaps.