Paradigm's recent opinion letter is quite pragmatic, with a 180-day approval period plus correction procedures, leaving a way out for state-level stablecoins. Don't wait for OCC detailed rules to be released before shutting the door.

CoinWorld News reports that Wu said to have learned 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 the state-level stablecoin regulatory framework 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 the state-level issuance pathway, including: before the OCC-related implementation rules are finalized, the rulemaking should not be completed; a 180-day approval period, correction procedures, and specific reasons for rejection should be set for the state-level regulatory framework certification; and allowing states to set operational expenditure safeguards based on issuer size and risk profile, rather than 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 limits or hindering cross-state operations.