Circle Urges “Same Activity, Same Rules” For GENIUS Act Stablecoins

Core Viewpoint - Circle submitted a comment letter to the U.S. Department of the Treasury regarding the GENIUS Act, advocating for a national framework for payment stablecoins that supports users, issuers, and intermediaries across U.S. markets [1] Policy Principles and Supervision - Circle proposes that payment stablecoins be fully backed by cash and high-quality liquid assets, kept separate from company funds, and redeemable at par on demand, with independent monthly checks and plain language reports for verification [3] - The company emphasizes a level playing field for both bank and nonbank issuers under a common prudential baseline, and calls for a reciprocal path for foreign regimes that meet GENIUS standards [4] - Circle supports predictable penalties and safe harbor protections for compliance with lawful orders, along with tested wind-down plans for quick and fair return of customer funds across borders [5] Market Use, Global Reach, and Accounting Treatment - Circle requests clarification from the Treasury on how permitted U.S. issuers can operate globally to ensure practical conversion between dollars and tokens for businesses [6] - The submission recommends that permitted payment stablecoins be treated as cash and cash equivalents for accounting and tax purposes, aligning financial reporting with the fully reserved model [7]