OCC rules haven't been implemented yet, and you're eager to set the regulations? Paradigm's letter of opinion is like handing the Treasury a ladder; let's wait and see how the federal government plays its hand.

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.