POPA ReconThe Blockchain Association filed comments on Oct 19, 2026 on Treasury's proposed rule implementing Section 3 of the GENIUS Act, covering who can issue, offer and sell payment stablecoins in the U.S. (post, letter page).
It applauded Treasury's effort but said the final rule should match what Congress wrote with clearer lines. (post).
On "digital asset service provider" it said Congress meant customer-facing businesses, excluding core infrastructure like self-custody software and validators, and firms trading their own assets should not be swept in. (post).
On criminal liability for "knowingly participating" in unlawful issuance, it said ordinary market making in "newly issued" coins could qualify as proposed and urged actual knowledge plus substantial assistance in coordination with the issuer. (post).
On foreign-issued coins, it said open-ended diligence on foreign issuers with no exchange relationship is unworkable and firms should rely on Congress's public registered-issuer lists and trading bans. (post).
On location on permissionless protocols where a firm may see only a wallet address, it said replace the "reasonable belief" standard with actual knowledge and information gathered in the ordinary course. (post).
It also asked Treasury to rule out an open-ended "functional equivalent" test for monetary value, revisit cost estimates, and align the effective date with related GENIUS Act rules. (post).
Cointelegraph flagged the filing the same day as urging clearer definitions and narrower liability. (post).