Circle has called on the Office of the Comptroller of the Currency (OCC) to finalize the GENIUS Act rules for payment stablecoin issuers, emphasizing the need for a clear and consistent regulatory framework. The company supports a national licensing regime that would ensure reliable redemption and robust risk controls for dollar-backed digital payment instruments. Circle's submission to the OCC highlights the importance of uniform standards to reduce arbitrage, protect users, and support trusted digital dollars. The OCC's proposed framework includes standards for reserves, redemption, information security, and operational readiness, applicable to national banks, federal savings associations, and certain state-qualified issuers. Circle advocates for these requirements to reflect the demands on major payment stablecoin issuers, ensuring 24/7 functionality and transferability across platforms. The company argues that stablecoin oversight should not vary by issuer type, as uneven standards could undermine trust and create competitive disadvantages. Circle believes that with clear rules, the U.S. can protect consumers and strengthen the role of digital dollars globally.