Circle Submits Comment Letter to SEC, Proposing Compliant Payment Stablecoins Be Treated as "Cash" and Broker-Dealer Haircut Cut to Zero

October 28: According to Circle's official blog, Circle recently submitted a comment letter on the U.S. SEC's proposed Regulation Crypto Assets. Circle recommends that the rule be consistent with the GENIUS Act and asks the SEC to clarify that payment stablecoins compliant with the GENIUS Act qualify as "cash" under proposed rule 302(b), are denominated in U.S. dollars, and are subject to the corresponding accounting and customer reserve treatment. Circle also recommends that, subject to objective safeguards being in place, the 2% haircut applied to broker-dealers holding such stablecoins be reduced to zero. In addition, Circle asks the SEC to clarify that technical services after a network becomes operational, including maintaining a known validator set, do not constitute "critical managerial efforts," and to establish a safe harbor for technical roadmaps.