This move by DFS essentially locks down stablecoin regulation. Is a 10-day comment period enough for anything?

The New York State Department of Financial Services (DFS) announced a new rule proposal aimed at upgrading and adjusting New York's current dollar stablecoin regulatory framework in accordance with the requirements of the GENIUS Act.
The proposal retains New York's previous strict requirements for compliant dollar stablecoins regarding asset backing, convertibility, permitted reserve asset types, and independent audits, while introducing new federal provisions, including limiting the maximum proportion of reserve assets that can be held in a single custodian and requiring issuing entities to establish comprehensive risk management plans covering internal controls, information security, internal audits, asset growth, related-party transactions, and service provider arrangements.
The proposal is now open for a 10-day pre-proposal public comment period.