This week decoded
GENIUS Act rulemaking returns to the forefront, as the OCC becomes the first agency to finalize rules. The final rule drops a provision from the earlier proposal that would have more explicitly policed relationships between stablecoin issuers and third-party exchanges, and it gives issuers more flexibility on reserve management. The OCC also asked for comments on issuer application and reporting forms.
The first contours of congressional oversight of the digital asset industry continue to emerge.
Read more below
Congress
Hearings
Congress returns in November after the midterm elections.
Legislation
Sen. Steve Daines (R-MT) officially introduced the Aligning Digital Assets with Principles of Taxation (ADAPT) Act to amend Internal Revenue Code provisions affecting digital asset taxation. (Text)
Correspondence
Senate Permanent Subcommittee on Investigations (PSI) Ranking Member Richard Blumenthal (D-CT) sent a letter to Tether CEO Paolo Ardoino requesting information about Tether’s reported multimillion-dollar payment to a consulting firm co-founded and controlled by Bo Hines while he served as the Executive Director of the White House Council of Advisers for Digital Assets. (Letter)
Blumenthal sent a similar letter to Nxum Group CEO Todd Hines seeking records and information related to contracts, payments, communications, and lobbying between Nxum, Bo Hines, and all associated parties. (Letter)
Blumenthal and Reps. Paul Tonko (D-NY) and Valerie Foushee (D-NC) sent letters to BetMGM, Caesars, DraftKings, Fanatics, Kalshi, and Polymarket, requesting information about VIP programs and potential exploitation of vulnerable bettors. (Letter)
Trump Administration
Office of the Comptroller of the Currency (OCC)
The OCC issued a final rule implementing the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act by establishing requirements for permitted payment stablecoin issuers and foreign payment stablecoin issuers under the OCC’s jurisdiction, as well as certain custody activities conducted by OCC-supervised entities. (Rule)
The OCC published requests for comment on GENIUS Act payment stablecoin issuer application forms (Federal Register), information collection and reporting forms (Federal Register) and information returns and schedules (Federal Register). The comment period ends November 23. The notices also indicate the OCC submitted these forms for OMB review.
Securities and Exchange Commission (SEC)
On November 9, the SEC will host a roundtable on machine‑understandable data and super intelligence (SI) to discuss how market participants use SI and machine‑understandable data, the associated risks and costs, and ways the SEC can further support and enhance the use of these technologies. (Event)
Noteworthy Quotes
ADMINISTRATION
Office of the Comptroller of the Currency (OCC)
The OCC posted “The OCC is committed to supporting a strong community banking sector as payment innovation advances. The effect of stablecoin adoption on community bank deposits remains uncertain, and estimates vary widely. The OCC takes community banks’ funding concerns seriously and is closely monitoring potential deposit outflows as the industry develops.”
The OCC also posted “President Trump signed the GENIUS Act into law to reshore innovation, reassert dollar dominance, and cement America’s leadership in digital assets. USComptroller Jonathan Gould discussed the OCC’s final rule to implement this historic legislation and create a federal framework around payment stablecoins from the floor of the NYSE as the Trump Administration propels American capital markets into the future.”
The OCC also posted “The GENIUS Act final rule advances POTUS’ and SecScottBessent’s vision for American leadership in digital assets. The USOCC is providing a clear, practical framework for payment stablecoin innovation, with strong standards for reserve backing, redemption, and risk management.”
The OCC also posted “USComptroller Jonathan V. Gould: Today’s final rule advances POTUS Trump’s and SecScottBessent’s vision for American leadership in digital assets. We are providing a clear, practical framework for payment stablecoin innovation, with strong standards for reserve backing, redemption, and risk management. The OCC is drawing on its longstanding supervisory expertise to support responsible growth and innovation for this new industry.”
Treasury Department
Secretary Scott Bessent posted “The GENIUS Act marks a watershed moment in American finance, further cementing the United States as the crypto capital of the world. Just as President Abraham Lincoln’s National Currency Act of 1863 established a national framework for bank-issued currency, the GENIUS Act establishes a federal framework for payment stablecoins in the digital age. The USOCC’s final rule carries that landmark legislation forward, providing a clear, practical foundation for private-sector innovation, competition, and American leadership in digital assets.”
Commodity Futures Trading Commission (CFTC)
Chair Mike Selig posted “Unlike casino-style gambling, CFTC-regulated prediction markets operate under a federal regulatory system designed to protect market integrity and prevent manipulation. Conflating the two ignores the fundamental distinction between gambling and regulated financial markets.”
Selig also posted “Market manipulation has no place in CFTC-regulated markets.
With the midterm elections approaching, the CFTC is closely monitoring prediction markets for attempts to distort trading activity or manipulate outcomes. Let me be clear: Those who manipulate our markets will be held accountable.”Selig also posted “Prediction markets offer Americans a new way to gauge what’s happening in the world, and as they grow, so does the need for federal oversight. At the CFTC, we are closely monitoring trading activity to uphold the gold standard of market integrity.”
Selig also posted “America cannot lead on the new frontier of finance with outdated and anachronistic regulations that force economic activity offshore. That’s why the CFTC proposed a pathway for crypto exchanges to opt in to a federal regulatory framework designed for national markets, with robust customer protections and clear rules for margin trading. Bankless”
Selig also posted “Regulatory certainty in crypto markets shouldn’t come with an expiration date. I’m committed to working across the aisle to establish clear, durable rules of the road that provide lasting regulatory certainty and stand the test of time.”
White House
The White House posted “SOON AT THE WHITE HOUSE: President Donald J. Trump highlights the admin’s efforts to crack down on foreign criminal networks that lure Americans into fraudulent crypto investments.”
CONGRESS
GENIUS Act
Sen. Katie Boyd Britt (R-AL) posted “I was proud to help pass the GENIUS Act last year. With this final rule, our agencies can get to work on implementing a clear regulatory framework for payment stablecoins, driving innovation here at home and cementing American leadership in digital assets.”
Sen. Bill Hagerty (R-TN) posted “By implementing the GENIUS Act, the Trump Administration paves the way to faster payments, more innovation, and stronger demand for U.S. Treasuries. Sound implementation of my legislation is critical to securing American leadership in digital asset innovation.”
Prediction Markets
Rep. Josh Riley (D-NY) posted “Elected officials should be focused on serving their communities, not lining their own pockets. That’s why I introduced the Drain the Swamp Act to BAN members of Congress from trading stocks and betting on prediction markets.”
Rep. Gabe Vasquez (D-NM) posted “If the CFTC Commissioner can’t tell the difference between a ‘prediction’ and a sports bet — it’s a bet. I’m calling out prediction markets who are circumventing New Mexico’s Tribal gaming compacts and taking valuable resources away from our Tribes and Pueblos, and working to put an end to it.”
CLARITY Act
Sen. Cynthia Lummis (R-WY) posted “Democrats suggested that anyone convicted of a felony involving insider trading, money laundering, terrorist financing, or financial fraud in the last ten years be barred from raising money under Regulation Crypto, and we agreed. The Clarity Act bars them. Democrats voted against keeping convicted criminals away from your savings.”
Lummis also posted “Democrats demanded that state attorneys general have the power to sue digital asset exchanges directly and even sue Washington if it fails to enforce the law. It was in the Clarity Act, but Democrats still voted no.”
Lummis also posted “Democrats wanted higher civil monetary penalties enforced by the Justice Department for digital asset violations. The Clarity Act raises them. Democrats voted no on the motion to proceed, effectively saying they felt imposing tougher penalties on crypto crime wasn’t even worth a debate, let alone passing.”
Lummis also posted “Democrats wanted digital commodity exchanges to file certified annual financial statements with the CFTC. The Clarity Act requires it. Democrats voted against protecting investors with certified financial statements.”
About Zero One Strategies
Zero One Strategies is a specialized government relations practice dedicated to navigating the complex landscape of U.S. federal policy in emerging technologies. As advancements in technology continue to outpace regulatory frameworks, Zero One Strategies aims to provide strategic guidance and bipartisan advocacy for innovators and businesses operating at the forefront of technological development.
The practice focuses on key areas such as artificial intelligence, digital assets, blockchain, decentralized technologies, cybersecurity, data, and digital infrastructure, as well as the multiple policy issues impacting these sectors, including tax and financial services.
Contact us at Stacey@ZeroOneStrategies.com
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