The Bank Policy Institute, The Clearing House Association, and the Consumer Bankers Association submitted a letter commenting on an FDIC proposed rule to implement the GENIUS Act. The letter supports the FDIC’s proposed regulatory changes to clarify that tokenized deposits are eligible for deposit insurance to the same extent as traditional deposits. The Associations assert that whether a deposit is recorded or represented using traditional banking systems, blockchain, or distributed ledger technology should not affect its status as an insured deposit under the Federal Deposit Insurance Act.

The Associations also support the FDIC’s proposal to make its recordkeeping requirements technology-neutral, allowing banks to use distributed ledger technology to maintain deposit records and comply with deposit insurance determination rules. They explain that existing requirements under FDIC regulations can be satisfied using blockchain-based systems, provided banks can identify account ownership, balances, and insurance coverage and meet reporting and operational requirements. The letter concludes that the proposed amendments would provide valuable regulatory clarity while preserving deposit insurance protections for innovative deposit products, and encourages continued FDIC engagement as banks develop tokenized deposit offerings. To read the full letter click here.