Notabene's Response to the Department of the Treasury Notice of Proposed Rulemaking: GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale

On 19 October 2026, Notabene filed its response to the Department of the Treasury’s Notice of Proposed Rulemaking on GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale, which implements section 3 of the Act.

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The earlier GENIUS Act rules covered how a licensed issuer runs its compliance program. This one decides who is allowed to issue, offer and sell payment stablecoins to people in the US at all.

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Our core position: Treasury chose the right test by basing it on where the parties to a transaction are located, backed by a reasonable belief standard. We showed it why that check has to happen before a transfer settles, since on an irreversible ledger a check run afterwards only records what already happened.”