National Cryptocurrency Association Urges Treasury to Protect Stablecoin Holders

The National Cryptocurrency Association is urging the U.S. Treasury to preserve access to existing stablecoin holdings as it develops GENIUS Act rules that will restrict issuance and some sales.

The group said it submitted comments Oct. 19 and publicly identified stolen-fund recovery and self-custody as priorities alongside access to existing holdings. “Treasury’s rules must ensure that Americans are not stranded holding stablecoins if regulations change,” wrote Ripple Chief Legal Officer and National Cryptocurrency Association President Stuart Alderoty.

The GENIUS Act became law July 18, 2025. Treasury published its proposed rule Aug. 18, 2026, and the comment period closed Oct. 19. The proposal addresses who may issue payment stablecoins in the United States and which coins covered digital asset service providers may offer or sell to U.S. customers.

The general restriction on unlicensed U.S. payment stablecoin issuance is expected to take effect Jan. 18, 2027. A broader restriction on covered providers’ offers and sales begins July 18, 2028.

The July 2028 date governs providers’ activity. It does not set a deadline for individuals to dispose of coins they already hold. The association’s call for continued access concerns how the rules will affect those existing holdings.

The law exempts qualifying direct transfers from Section 3 restrictions when both individuals act on their own behalf, for their own lawful purposes and without an intermediary. It also exempts transactions through software or hardware wallets used for a person’s own custody. Both exemptions are already in law and appear in Treasury’s draft.

The proposal also provides for issuers to reissue stablecoins when a lawful order requires it. That provision does not establish a general stolen-fund recovery process. Treasury is considering whether to add limited transition protections, which would be separate from the exemptions already in place.

Treasury will decide whether to add transition protections when it finalizes the regulations.