Circle submits comment letter on the SEC's proposed crypto asset regulation rules.

October 28: Circle has submitted comments to the U.S. Securities and Exchange Commission regarding its proposed crypto asset regulatory rules. Circle supports the proposal's goal of promoting innovation under clear rules while maintaining the advantages of U.S. capital markets, including transparency, investor protection, market integrity, liquidity, and efficiency. Circle also recommends that the crypto asset regulatory rules be aligned with the GENIUS Act. Given that payment stablecoins are increasingly becoming an important consideration and settlement asset for on-chain capital formation, Circle requests that the U.S. Securities and Exchange Commission (SEC) clarify how payment stablecoins that comply with the GENIUS Act provisions can be used for these purposes.

The letter further asks the Commission to clarify that eligible payment stablecoins constitute "cash" under proposed rule 302(b), should receive appropriate U.S. dollar valuation treatment, and meet the corresponding accounting and customer reserve treatment conditions. Circle also recommends that, subject to objective safeguard measures, the current 2% broker-dealer haircut for payment stablecoins that comply with GENIUS be reduced to zero.

Finally, Circle requests that the SEC clarify that technical services provided after a network goes into operation (including maintaining a known set of validator nodes) do not constitute necessary administrative management work. Establishing a safe harbor rule for technical roadmaps would allow issuers to continue maintaining and improving an operating network without inadvertently restarting the relevant analysis.