I just finished reading Christopher and Andrea’s paper Regulating Stablecoins: Comparing MiCAR and the GENIUS Act. Their work highlights contractual weaknesses in the terms of use of major stablecoin issuers, including one-sided provisions, vague redemption timelines, and unclear customer bankruptcy protections. They argue these issues are not inherent to stablecoin technology and can be addressed through modest contractual revisions. Now that the GENIUS Act has been signed into law, we are entering the implementation phase—when regulators at the OCC and Treasury will begin crafting the rules and application process for onboarding GENIUS-compliant stablecoins. As part of that process, existing issuers such as Circle and Tether will need to apply to Treasury for approval of their stablecoins. At this early stage, the application process remains unclear. While the Act does not explicitly require regulators to review an issuer’s Terms of Service, the OCC and Treasury have broad authority to evaluate whether an issuer’s operations meet statutory objectives. This provides an opportunity for regulators to engage with stablecoin issuers on revising their terms—not only to comply with GENIUS Act requirements, but also to address the concerns raised in Christopher and Andrea’s paper. For example, as a condition of approval, regulators could require revised terms that guarantee timely redemption, establish direct contractual privity with all holders, grant holders clear priority claims over reserves in insolvency, and use plain-language disclosures. Integrating this review into the approval process would align contractual rights with the Act’s operational safeguards, strengthen consumer protection, and enhance the credibility of U.S.-approved stablecoins in both domestic and global markets. Thanks for sharing your paper. I am currently compiling a list of proposed comments and concerns from key crypto-sector figures that regulators should consider as they begin the GENIUS Act rulemaking process. I’d welcome your thoughts on this proposed remedy, and I’d like to hear from others in the sector and in government so we can ensure we get this right. I’m happy to advise and consult on this and other GENIUS Act related issues. Thanks, Carlo Founder and Chief Strategist @circle @jerallaire @ddisparte @Tether_to @paoloardoino @USTreasury @USOCC