Circle submitted a comment letter on the proposed cryptocurrency asset regulatory regulations by the SEC

Circle submitted comments to the U.S. Securities and Exchange Commission regarding its proposed regulatory framework for cryptocurrency assets. Circle supports the proposal's goal of fostering innovation under clear rules while maintaining the advantages of U.S. capital markets, including transparency, investor protection, market integrity, liquidity, and efficiency.

Circle also suggested that the cryptocurrency asset regulatory framework should align with the GENIUS Act. Given that payment stablecoins are increasingly becoming important considerations and settlement assets for on-chain capital formation, Circle requests that the U.S. Securities and Exchange Commission (SEC) clarify how payment stablecoins that comply with the provisions of the GENIUS Act can be used for these purposes.

The letter further requests that the Commission clarify that eligible payment stablecoins constitute "cash" under proposed Rule 302(b), should receive appropriate U.S. dollar valuation treatment, and comply with the corresponding accounting and customer reserve treatment conditions.

Circle also recommends that, provided objective safeguards are in place, the current 2% broker discount for payment stablecoins that comply with GENIUS be reduced to zero. Finally, Circle requests that the SEC clarify that technical services provided after the network goes live (including maintaining a known set of validating nodes) do not constitute necessary management work. Establishing safe harbor rules for the technical roadmap would allow issuers to continue maintaining and improving the operational network without inadvertently restarting the related analysis.