The American Bankers Association (ABA) has criticized the Office of the Comptroller of the Currency's final stablecoin rules implementing the GENIUS Act, arguing they contradict congressional intent to protect local credit. ABA CEO Rob Nichols pointed out that the new rules removed a provision from earlier proposals that presumed certain issuer-third party arrangements unlawful, effectively allowing platforms like Coinbase to continue offering yield on stablecoins to users. Nichols warned that this regulatory gap blurs the distinction between payment stablecoins and bank deposits, stating that addressing the issue only after deposit outflows occur is "the wrong approach." TD Cowen analyst Jaret Seiberg echoed concerns that the case-by-case assessment framework creates uncertainty for banks, noting that a future Comptroller appointed after the 2028 election could alter how evasion determinations are made. In contrast, Blockchain Association Chief Policy Officer Lindsay Fraser defended the rules, saying they adhere more closely to statutory text and provide clearer standards for issuers compared to earlier drafts.