On May 1, 2026, Catherine, as president of Solari, Inc., submitted comments in response to the Office of the Comptroller of the Currency’s (OCC’s) Notice of Proposed Rulemaking (NPRM) related to “Implementing the GENIUS Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the [OCC].”
The comments express four major concerns about the current version of the Proposed Rule:
- It does not adequately protect consumers.
- It fails to preserve financial privacy and liquidity.
- It does not safeguard local banking institutions from loss of deposits that fund bank credit to small businesses, farms, and individuals.
- It does not prevent the deployment of programmable money as a coercive surveillance and social control infrastructure.
The comments also offer six specific measures that the OCC can take to strengthen the Proposed Rule, stating that the rule must:
- Affirmatively preserve cash and non-programmable payment options as legally protected alternatives.
- Protect the credit-granting capacity of community and local banks and prohibit anticompetitive incentive structures.
- Guarantee consumer access to non-programmable digital and cash payment options.
- Close the “publicly available information” loophole and require privacy-protective technology.
- Prohibit government-mandated and issuer-implemented freezes, expirations, and spending restrictions without due process.
- Prohibit transaction denial based on protected characteristics, lawful activity, and viewpoint.
Read the full comments letter HERE.
