Paradigm’s move is very practical—an 180-day buffer period plus a correction mechanism gives state-level stablecoin(s) enough breathing room.

Paradigm submits a letter to the Department of the Treasury, recommending revisions to the "substantial similarity" rule in the GENIUS Act state-level stablecoin framework: not finalizing the rule before OCC implementation details are determined; establishing a 180-day certification period with correction and rejection reason explanations; allowing states to set operational expense safeguards based on issuance scale and risk; restricting states from imposing additional constraints on issuers through expanding revenue restrictions or hindering cross-state operations.