According to Paradigm's official blog, the company submitted comments to the U.S. Department of the Treasury on June 3rd regarding the regulatory pathway rules for the "GENIUS Act" at the state level. Paradigm supports the core framework of the proposal but points out that four modifications are necessary to enable the state-level channel to effectively serve issuers. Key recommendations include: anchoring the federal framework to the finalized OCC regulatory regulations, establishing a 180-day decision period for three-agency certification, and setting clear rejection standards; allowing states to adjust the 12-month operational reserve requirements based on issuer size and risk profile; and addressing gaps in preventing hostile state-level actions.