Wu said that the crypto venture capital firm Paradigm submitted a comment letter to the U.S. Department of the Treasury, proposing amendments to the "substantive similarity" criteria for state-level stablecoin regulation under the GENIUS Act. Paradigm supports the overall framework proposed by the Treasury Department but believes that some provisions may affect the practical viability of state-level issuance pathways, including: that the rule should not be finalized before the OCC-related implementation details are finalized; a 180-day approval period, correction procedures, and specific reasons for rejection should be established for state-level regulatory framework certification; allowing states to set operational expense coverage requirements based on issuer size and risk profile instead of a uniform requirement covering 12 months of operating costs; and explicitly restricting individual states from imposing additional constraints on state-level stablecoin issuers through expanded revenue restrictions or hindering cross-state operations.