Letter emphasizes need for objective approval standards, regulatory coordination, and flexible subsidiary structures to support responsible innovation

Washington, D.C. (May 19, 2026) – The American Fintech Council (AFC), the largest industry association representing both responsible fintech companies and innovative banks, submitted a letter in response to the Federal Deposit Insurance Corporation’s (FDIC) Notice of Proposed Rulemaking implementing approval requirements for the issuance of payment stablecoins under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The letter underscores the importance of establishing a clear, consistent, and administrable framework that enables insured depository institutions to participate responsibly in stablecoin issuance while preserving their safety and soundness.

“The FDIC’s approach to implementing the GENIUS Act will play a defining role in determining whether stablecoin innovation develops within the regulated banking system,” said Phil Goldfeder, CEO of the American Fintech Council. “A transparent and predictable approval process is essential to ensuring that responsible financial institutions can engage in this activity in a safe, sound, and well-supervised manner.”

In its letter, AFC calls for clear, objective, and time-bound approval standards to reduce uncertainty, emphasizing that greater specificity around evaluation criteria is critical to enabling institutions to structure proposals and allocate resources efficiently. AFC also supports a flexible subsidiary framework that allows integration with parent bank risk management systems, cautioning that overly rigid structural requirements could create operational inefficiencies without improving risk outcomes.

“A clear and coordinated regulatory framework is important to fostering responsible innovation in digital assets,” said Ian P. Moloney, Chief Policy Officer of the American Fintech Council. “Providing clarity on approval standards, capital and liquidity treatment, and regulatory expectations will give institutions the confidence to engage in stablecoin issuance in a manner that supports both financial stability and continued innovation. As the FDIC joins its fellow prudential regulators in implementing the GENIUS Act, we encourage proper coordination to ensure a regulatory framework that can be consistently applied across the industry.”

Additionally, AFC emphasizes the importance of avoiding duplicative or overlapping regulatory requirements across agencies implementing the GENIUS Act, urging the FDIC to coordinate closely with other regulators to ensure its approval process does not replicate existing supervisory frameworks. AFC further calls for clear guidance on how stablecoin-related activities will be treated for purposes of capital, liquidity, and balance sheet management, noting that consistent and transparent standards are essential to reduce uncertainty and enable institutions to evaluate participation with confidence.

A standards-based organization, the American Fintech Council (AFC) is the largest and most diverse trade association representing financial technology (fintech) companies and innovative banks. On behalf of over 150 member companies and partners, AFC promotes a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.

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