Circle Asks SEC to Approve Rules for Stablecoins with GENIUS Act

Circle outlined its views on how payment stablecoins should fit into the SEC's proposed regime for crypto assets. The summary from October 28 describes a comment letter submitted on October 20, 2026: the requests concern the recognition of stablecoins as cash, settlements for broker-dealers, and the role of technical work on blockchain networks. The letter is significant as it addresses the financial 'plumbing' of tokenized markets, not just the question of whether a token can be issued.

In the summary, Circle urges aligning Regulation Crypto Assets with the GENIUS Act and asks the SEC to clarify how qualified payment stablecoins can be used as a means of settlement and a settlement asset. The company also seeks recognition as cash under the proposed Rule 302(b) and a reduction of the haircut for broker-dealers from 2% to zero when safeguards are met. These are requests from an interested market participant: the letter does not mean the commission has accepted them, and the final version may differ significantly from the issuer's preferences.

Regulatory haircut is a deduction when recognizing an asset for a specific financial settlement. Its change affects the efficiency of balance sheet usage, even if the asset itself remains unchanged: two instruments with similar everyday use create different costs for an intermediary if the rules recognize them differently. To assess the letter, one must understand which stablecoins qualify, what safeguards apply, and whether the regime reflects the risks of actual asset use.

Placement does not end with a blockchain entry: the investor transfers value, the issuer receives it, and the intermediary accounts for balances. Clear rules reduce uncertainty in valuation, storage, and client reserves, but the status of cash should not obscure the legal requirement of the instrument and the conditions of its redemption.

Circle also requests clarification on how to interpret technical services after network launch: should ongoing maintenance differ from managerial efforts in creating an investment proposal. The final boundary depends on the final rules and their application, not just the company's description.

The next significant step will be formal action by the SEC or an updated proposal. Until then, claims that qualified stablecoins have already received a zero haircut or cash regime are beyond the scope of evidence.