On October 21, according to NewsBTC, the Blockchain Association submitted comments on the Treasury Department's proposed Rule 3 under the GENIUS Act, calling for clearer delineations regarding software, overseas stablecoin issuers, and liability. The association argues that a regulatory framework designed for licensed payment service providers should not inadvertently encompass unrelated software or market participants.
One point of contention is the definition of "digital asset service provider," with the association advocating a distinction between customer‑facing financial services and infrastructure—such as self‑custody software or validator networks—that does not offer comparable services. Another issue concerns how to define "knowing participation" in the issuance of illicit stablecoins; the association argues that enforcement should be predicated on actual knowledge and substantive assistance, and that ordinary secondary‑market activity should not be treated as evidence of such involvement. Foreign stablecoin issuers are also under scrutiny; the association maintains that compliance requirements should be grounded in available regulatory information, rather than assuming that every service provider can investigate issuers with whom they have no direct relationship. The report underscores that these positions represent industry‑advocated stances, not amendments already adopted by the Treasury Department, and that the final wording will determine whether the GENIUS Act's compliance obligations fall primarily on stablecoin issuers or extend more broadly to the wider ecosystem.