The Clearing House Association and the Bank Policy Institute submitted a joint comment letter on FinCEN’s proposal to establish Customer Identification Program requirements for permitted payment stablecoin issuers under the GENIUS Act. The Associations generally support the proposed framework but recommend additional clarification to ensure consistent treatment across the broader GENIUS Act regulatory regime and the existing Bank Secrecy Act framework. In particular, the letter urges regulators to clarify CIP obligations for secondary-market intermediaries, address how customer onboarding requirements interact with direct stablecoin redemptions, and refine the definitions of “customer” and “account” to reduce uncertainty and avoid unintended regulatory gaps. To read the full letter, click here.