Banks Challenge OCC’s Weekly Stablecoin Reporting Burden

Comment letters filed with the Office of the Comptroller of the Currency show where implementation of federal stablecoin regulation may require further work, particularly around the information regulators expect issuers to produce regularly.

The OCC is focused on proposed reporting forms for permitted payment stablecoin issuers under its jurisdiction, and the agency closed its initial comment period Tuesday (Aug. 11). The proposal would establish confidential weekly reports and quarterly financial condition reports. It follows the OCC’s March proposal implementing the GENIUS Act, which has not been finalized. The OCC has said changes to that rule could result in changes to the reporting forms.

The proposed forms cover more than the composition of reserves. Weekly reports would include issuance and redemption activity, exchanges, trading volume, large wallet holders and counterparties, along with detailed information about the assets backing each stablecoin.

Comments from the Bank Policy Institute and American Bankers Association, as well as the Conference of State Bank Supervisors, addressed how the requirements could work in practice. An April 29 XBRL US comment on the OCC’s broader GENIUS Act proposal, while not part of the Aug. 11 reporting form docket, also addressed reporting questions relevant to the forms now under consideration.

Reserve Visibility

The OCC’s proposed weekly schedules would give supervisors detailed information about the assets backing stablecoins.

For Treasury securities, issuers could be required to report individual CUSIP numbers, fair value, remaining maturity, coupon and effective interest rates, custodians, and information about Treasuries encumbered by repurchase agreements. Other schedules cover cash, reverse repos, money market funds and additional reserve instruments.

BPI and ABA recommended reducing at least some of that detail. In a joint letter, they described individual Treasury CUSIP reporting as a “substantial burden” and suggested that the OCC instead collect aggregated Treasury information.

The groups also questioned the proposed requirement to identify the portion of reserve assets held in tokenized form. They argued for a “technology-neutral approach,” saying that a tokenized Treasury and a non-tokenized Treasury represent the same claim on the U.S. government for reserve purposes.

If the OCC retains that requirement, BPI and ABA recommended allowing issuers to report tokenized holdings within percentage ranges and clarifying what qualifies as a tokenized reserve asset.

The OCC also proposed collecting information that would give supervisors a regular view of activity surrounding the stablecoin itself.

Schedule A would include large holders identified by wallet address, exchanges facilitating trading, trading volume and major counterparties. Schedule B would cover issuance and redemption as well as secondary market price and trading information. That data could help the OCC monitor primary and secondary markets, including during periods of stress.

The frequency of that reporting was one concern raised by the banking groups, which seek additional time for issuers to prepare and validate weekly reports. They recommended reducing duplication by automatically populating common data fields where possible and aligning stablecoin reporting terminology with Call Report instructions.

Public Transparency and Data Format

The OCC proposed a different treatment for weekly and quarterly information. Weekly reports would remain confidential, while the agency intends to publish quarterly reports so the public can follow issuers’ financial condition.

The April 29 XBRL US letter addressed how that information could be structured and distributed. It recommended structured, machine-readable reporting and argued that issuers already submitting XBRL-formatted Call Reports should be able to reuse those filings for overlapping information.

It also recommended making weekly information publicly available and said machine-readable data could allow automated validation and alerts when specified thresholds are reached.

BPI and ABA pointed to differences between the OCC proposal and the Federal Deposit Insurance Corp.’s approach. The FDIC has proposed collecting less weekly information from issuers with less than $1 billion in outstanding issuance and less than $100 million in average daily transaction volume during the previous month. The bank groups recommended that federal regulators coordinate so their reporting requirements are “substantially similar.” CSBS said it also favors common reporting requirements.

The Aug. 11 deadline completes the first comment period, not the information collection process. The OCC’s notice said it will publish a second notice providing another 30-day comment period before the collection proceeds through the Paperwork Reduction Act process.

There is also sequencing to resolve. BPI and ABA said in their letter that the OCC should finalize the substantive GENIUS Act requirements first and then repropose reporting forms that reflect those final requirements. The OCC itself acknowledged that its current forms may need modification because the underlying rule remains pending.

The comments therefore leave several decisions with the OCC, including the appropriate level of reserve detail, the amount of time issuers receive to validate weekly data, how existing bank reports can be reused, what information becomes public, and how closely reporting should be coordinated across regulators.