Notabene's Response to the Joint Notice of Proposed Rulemaking

On 21 August 2026, Notabene filed its response to the joint Notice of Proposed Rulemaking on the Permitted Payment Stablecoin Issuer Customer Identification Program — issued by FinCEN, the OCC, the Federal Reserve, the FDIC, and the NCUA under the GENIUS Act.

It's our fourth filing in the GENIUS Act rulemaking series, and the first addressed to all five agencies at once.

Our core position: the agencies got the hard part right by limiting an issuer's identification duty to the customers it deals with directly, not everyone who ends up holding its token — and we told them exactly which regulated layer should cover everyone else.