FEDERAL MONEY SERVICES BUSINESS ASSOCIATION INC.

S. 1582, GENIUS Act (payment stablecoin licensing). In early July, 2025, FedMSB sent a Congress letter and a technical amendment urging targeted changes so the bill modernizes payments without displacing the MSB framework. Requested four clarifications: (1) affirm that non-bank stablecoin issuance/redemption is money transmission under 31 CFR 1010.100(ff) and remains subject to MSB registration/compliance; (2) codify FinCENs primary AML authority; (3) preserve state Money Transmitter Licenses (MTLs) from federal preemption; and (4) revise the bills terminology to treat stablecoins as a digital payment instrument, not a generic digital asset, to avoid regulatory overlap and misclassification. Rationale included concerns about preemption, duplicative/conflicting regimes, and concentration of discretionary licensing authority (e.g., OCC) that could invite politicization. Overall position: modernize, dont replace-integrate stablecoins into the existing federal-state MSB supervisory structure.