Paradigm submitted a comment letter to the U.S. Department of the Treasury regarding the state-level regulatory path of the GENIUS Act

According to the official blog, Paradigm has submitted a comment letter to the U.S. Department of the Treasury regarding the rulemaking for state-level regulatory pathways under the GENIUS Act. Paradigm supports the core framework of the proposal but points out that without addressing four issues, the state-level pathway will not effectively serve issuers.

First, the proposal anchors the federal framework to the yet-to-be-finalized OCC regulations, requiring states and issuers to plan based on an undecided benchmark, which directly hinders market access. The Treasury should not finalize this rule before the OCC's implementation rules are finalized.

Second, the proposal requires unanimous agreement from the heads of the Treasury, the Federal Reserve, and the FDIC to certify the state-level system, but does not set a decision timeline, veto explanation standards, or mechanisms to prevent a single member from indefinitely blocking certification. Paradigm suggests establishing a 180-day decision deadline, creating a corrective process for supplementary submissions, and requiring specific veto explanations.

Third, the proposal mandates that the state-level system maintain a reserve fund for 12 months of operating expenses, which may crowd out early issuers. It is suggested that states be allowed to adjust reserve fund requirements based on the size and risk profile of the issuer. Fourth, the proposal fails to adequately preempt hostile actions from individual states, and this loophole must be addressed.