While Congress debated market structure, federal agencies moved ahead on updating and modernizing their rulebooks to provide regulatory clarity under their existing authorities. Since January, CCI has filed more than 25 comment letters and written submissions to help guide federal regulators towards adopting durable, workable rules that promote responsible innovation. These initiatives have included advocacy efforts across Treasury, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), the Federal Reserve Board (Board), the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), and more. This report looks back at this year’s regulatory highlights.
Implementing the GENIUS Act
The GENIUS Act represents historic legislation, providing the first comprehensive framework for the issuance of payment stablecoins. Treasury and the Federal payment stablecoins regulators (such as the OCC, FDIC, and Board) are now working to implement this Act’s licensing, supervision, consumer protection, and financial stability requirements.
- Federal Payment Stablecoin Regulators: CCI has filed comments urging Federal payment stablecoin regulators not to expand the GENIUS Act’s intentionally narrow yield prohibition beyond the statute’s explicit language, clearly permit issuers to issue multiple stablecoin brands under one license, and ensure issuers retain sufficient flexibility to manage reserve assets, redemption policies, and capital requirements tailored to their business model and subject to robust consumer protections. More broadly, CCI has emphasized the importance of promoting regulatory parity so issuers compete on a level-playing field.
- Treasury: In response to Treasury’s proposal for determining whether a State’s payment stablecoin regime is “substantially similar” to the federal framework, CCI urged Treasury to adopt principles that ensure State regimes Act’s section 4(a) requirements to preserve the fungibility of GENIUS-compliant stablecoins.
- FinCEN: GENIUS includes robust anti-illicit finance safeguards. CCI has advocated for effective AML/CFT and sanctions compliance program requirements for permitted payment stablecoin issuers, including through comment letters to FinCEN addressing the scope of illicit finance obligations, compliance with lawful orders, and leveraging blockchain technology to detect and counter illicit finance involving payment stablecoins.
- Unlawful stablecoins: CCI submitted a response to Treasury’s proposed rule implementing the Act’s prohibitions on unlawful issuance, offer, and making available payment stablecoins in the U.S. The letter offers recommendations to clarify scope and ensure issuers are not able to circumvent the Act.
Access to payment rails
- CCI responded to the Board’ request for information (RFI) on its proposal to establish limited purpose “Payment Accounts” at Federal Reserve Banks. CCI supported the Board’s objective of expanding access to Federal Reserve payment services to a greater number of legally eligible institutions, subject to appropriate risk-mitigating safeguards. When the Board followed up its RFI with a formal proposal, CCI appreciated the Board expanding the balance caps on the proposed Payment Account terms, consistent with CCI’s recommendation.
- CCI’s comment letters have encouraged the Board to ensure the overnight closing balance limit does not unduly constrain Payments Accounts utility, allow at least minimal interest, include access to FedACH services as part of Payment Account services, and leverage existing illicit finance safeguards and supervision to protect against illicit finance risks.
SEC: Modernizing rules for tokenization, custody, and vaults
Under Chair Atkins, the SEC has advanced several proposals aimed at modernizing and clarifying existing rules to accommodate the unique aspects of crypto assets and blockchain technology. CCI has actively engaged the SEC on these initiatives to help the SEC develop a clear framework for onchain financial markets.
- Tokenized securities: On February 2, CCI and Superstate wrote in support of Project Crypto, urging the SEC to use all of its available tools, including its exemptive authority, to establish a regime for tokenized securities trading. In April, CCI joined a DeFi Education Fund-led coalition letter supporting clarity on when user interfaces need not register as broker-dealers.
- Custody: After meetings with the Division of Investment Management in February and March, CCI submitted guiding principles for a principles-based framework permitting registered investment advisers to self-custody crypto assets. The Commission has since published a comprehensive proposal to update custody rules for investment advisers and investment companies, including a framework under which RIAs may self-custody crypto assets. CCI is drafting a submission in support of this initiative and to further improve the workability of the proposal.
- Vaults: CCI launched its Vault Coalition at a private roundtable at Consensus in May and publicly at the Vault Summit in June. Anchor members briefed the SEC’s Crypto Task Force on July 20, and CCI is now crafting a written submission analyzing how the Securities Act, Investment Advisers Act, and Investment Company Act may apply to vault structures..
- Modernizing Rules For Digital Assets & Blockchain Technology: CCI has also supported the Commission’s efforts to modernize its existing rulebook while offering targeted recommendations to help future-proof rules and promote responsible digital asset innovation, including in comments on proposed rescissions to Regulation NMS, proposed Regulation E-Delivery, and a request for comment on novel ETFs. CCI has submitted comments to the SEC’s proposed Regulation Crypto Assets. CCI supports the proposed purpose-fit fundraising framework, which would include a tailored fundraising exemption for crypto entrepreneurs with purpose-fit disclosures and a safe harbor to clarify when investment contracts are no longer treated as securities, as well as preemptive relief from a patchwork of State securities laws. Looking ahead, CCI is now working on comments to address SEC proposals to update existing rules governing transfer agents to accommodate evolutions in the market and technological innovations, including tokenization and blockchain technology.
CFTC: prediction markets and new products
Like the SEC, the CFTC has also been committed to providing regulatory clarity for onchain financial markets, including by advancing Project Crypto as a joint initiative. CCI has consistently advocated for the CFTC to recognize and leverage how blockchain-based infrastructure can meet and advance the Commodity Exchange Act’s core objectives of protecting market integrity and end users, including in comments on two CFTC proposals on event contracts and public interest determinations.
- Over the August recess, CCI commented on extending standard futures contracts to 24/7 trading and on perpetual contracts referencing physically delivered or storable energy commodities, and it is now responding to the request for information on derivatives tied to AI compute.
- Building on our letter to the CFTC’s request for input on the President’s Working Group Recommendations at the end of last year, CCI has continued advocating and expressed support for CFTC initiatives to clarify the regulatory treatment of perpetual futures as futures (rather than swaps), unlock the use of digital assets as collateral, margin, and settlement tools, and clarify how existing registration, reporting, and supervisory requirements apply—or do not apply—to DeFi.
- CCI also submitted commentary to the Commission’s Request for Comment on the Listing of Compute Derivatives. Compute has emerged as a highly in-demand economic resource and an increasingly important input into the digital economy. Our submission chronicles the evolution of energy commodities and Bitcoin derivatives which demonstrate how derivatives markets can emerge alongside developing spot markets to provide price discovery, liquidity, and tools for managing price risk. We also explore how perpetual compute futures could provide useful risk-management features for market participants whose exposure to compute is continuous rather than tied to a discrete delivery date.
Other agencies
CCI’s advocacy work has spanned across a broad remit of federal agencies and policy objectives:
- Department of Labor: CCI filed a comment letter supporting the asset-neutral, process-driven approach in the DOL’s proposed rule, clarifying how 401(k) plan fiduciaries may satisfy their duty of prudence when selecting alternative investments.
- FinCEN: CCI filed a comment letter on a proposed rule modernizing AML/CFT program requirements under the Bank Secrecy Act, urging recognition of blockchain analytics and AI in evaluating program effectiveness.
- Federal Trade Commission: CCI, the DeFi Education Fund, the Blockchain Association, and the Solana Policy Institute jointly urged the FTC not to establish a de facto industry requirement for decentralized protocols to install kill switches or circuit breakers through its proposed order against Illusory Systems (Nomad), explaining how such a requirement would stifle decentralization. CCI discussed the letter with Chairman Ferguson in April.
- Patent policy: CCI wrote to Commerce Secretary Howard Lutnick and filed a comment letter to USPTO encouraging Commerce to restore meaningful access to the Patent Trial and Appeal Board (PTAB), which provides innovators the most efficient and timely venue to counter claims from non-practicing entities (i.e. patent trolls). CCI then joined a multi-association letter to the White House to demonstrate broad support across innovative industries to restore meaningful access to PTAB. CCI has also recommended measures to improve transparency on foreign litigation funding, and establish a crypto working group in the U.S. Patent and Trademark Office.
Looking Ahead
The rulemaking cycle that began this year is far from complete, and CCI will continue to serve as a technical resource to the agencies carrying out this important work.
The same holds on Capitol Hill. As Members continue to consider digital asset legislation, CCI remains committed to supplying the analysis and member expertise needed to inform thoughtful policy. As these legislative frameworks – including the GENIUS Act passed in 2025 – move from enactment to implementation, CCI looks forward to supporting Congressional oversight efforts, as well as members’ consideration of whether the resulting rules achieve sound policy outcomes.
