A federal comment window that could determine how U.S. stablecoin issuers identify their customers closes Friday, putting one of the most consequential pieces of GENIUS Act compliance plumbing into the hands of five regulators.
The June proposal is separate from the GENIUS Act rulemakings FinanceFeeds covered this week. Treasury on August 17 proposed rules for U.S. stablecoin issuers and foreign stablecoins, while the OCC is aiming to finalize its broader GENIUS Act rules by November. The document closing for comments today is the June customer identification program, or CIP, proposal — a different joint rulemaking focused specifically on who stablecoin issuers must identify and verify.
Five Agencies, One Stablecoin Rule
FinCEN issued the proposal jointly with the Office of the Comptroller of the Currency, Federal Reserve Board, Federal Deposit Insurance Corporation and National Credit Union Administration.
The Federal Register is explicit about the cutoff: “Comments must be received by August 21, 2026.”
The proposal implements the GENIUS Act’s directive to treat permitted payment stablecoin issuers as financial institutions for Bank Secrecy Act purposes and require them to maintain an effective customer identification program.
That does not mean every person holding a stablecoin on-chain would automatically become an issuer’s customer. The proposal centers on direct relationships with the issuer and excludes people whose only activity is acquiring or redeeming a stablecoin other than directly from or to the issuer. Ownership of a stablecoin alone, without another formal relationship, is also excluded.
For direct customers, however, the framework is much closer to banking-style onboarding: issuers would need written, risk-based procedures capable of forming a reasonable belief that they know the customer’s true identity.
Who Filed Before the Deadline
The public record visible through the Federal Reserve shows that the issue has attracted comments on the mechanics of digital identity rather than only broad arguments over whether stablecoins should face bank-style rules.
Independent payments and financial-market-infrastructure adviser Nico Paulo Mendoza filed a comment proposing that identity records be kept in structured, machine-readable fields and that verification records capture the source, method, date and result. He also proposed allowing Legal Entity Identifiers as supplementary identifiers for entity customers without replacing required taxpayer identification numbers.
The Fed’s public comment list also shows a filing from VeloxVFX LLC posted on August 17.
Those visible Fed records should not be treated as a complete tally of today’s submissions. The joint proposal allows comments through multiple agency channels and dockets, including FinCEN, OCC, the Fed, FDIC and NCUA, and filings received near the deadline may not appear publicly immediately.
What Happens After August 21
Today’s deadline does not start the compliance clock.
The agencies proposed giving permitted payment stablecoin issuers 12 months from issuance of the final rule to implement the CIP requirements. The implementation period therefore begins only after the agencies complete the rulemaking and publish a final rule.
The next phase is regulatory rather than legislative: the five agencies will review the record, decide how to handle contested areas such as direct redemptions, digital identity tools, reliance on another regulated institution’s CIP and the boundary between primary and secondary-market activity, and then move toward final text.
That makes August 21 important for a reason that has little to do with bitcoin’s daily price. The GENIUS Act established the framework. This proceeding is where regulators begin deciding what identifying a stablecoin customer will actually require — and today’s deadline closes the industry’s formal opportunity to shape that version of the rule before the five agencies write the final one.