Key Takeaways
- • Andreessen Horowitz (a16z) urged the New York State Department of Financial Services (NYDFS) in a Sept. 21 comment letter to withdraw and rewrite its proposed payment stablecoin rules (Part 202).
- • a16z warned that differences between New York's final rule and eventual federal requirements under the GENIUS Act could cause the Stablecoin Certification Review Committee to deny New York's certification.
- • The firm asked NYDFS to issue a revised rule only after federal standards from Treasury and the Office of the Comptroller of the Currency (OCC) are finalized.
- • The letter cited 383 comments across two federal proceedings: 55 on Treasury's proposal and 328 on the OCC's.
- • New York's draft would require issuers with at least $25 billion in outstanding payment stablecoins to hold at least 0.5% of reserves as insured deposits or insured shares each business day, capped at $500 million.
Summary
Andreessen Horowitz (a16z) has urged New York regulators to withdraw and rewrite proposed payment stablecoin rules, warning that differences from unfinished federal standards could put the state's certification at risk. The firm made the request in a Sept. 21 comment letter to the New York State Department of Financial Services (NYDFS), according to the source article published on TokenPost.
New York published its proposed Part 202 rule on July 22, while the Treasury and the Office of the Comptroller of the Currency (OCC) were still developing rules under the GENIUS Act. The law allows state-qualified payment stablecoin issuers with no more than $10 billion in consolidated outstanding issuance to opt for state supervision. That option requires the Stablecoin Certification Review Committee to approve the state's framework under a federal test of whether its rules are substantially similar to federal requirements.
a16z warned that differences between New York's final rule and the eventual federal requirements could lead the committee to deny New York's certification. Its letter cited 383 comments across two federal proceedings at the time: 55 on Treasury's proposal and 328 on the OCC's. The firm acknowledged that New York's draft already addresses some questions still under federal consideration. Among its provisions, issuers with at least $25 billion in outstanding payment stablecoins would have to maintain at least 0.5% of reserves as insured deposits or insured shares at an insured depository institution each business day, subject to a $500 million cap.
a16z argues that later federal changes could leave New York-regulated issuers facing conflicting requirements. Accordingly, the firm has asked NYDFS to issue a revised rule after the federal standards are final.
New York published its proposed Part 202 rule on July 22, while the Treasury and the Office of the Comptroller of the Currency (OCC) were still developing rules under the GENIUS Act. The law allows state-qualified payment stablecoin issuers with no more than $10 billion in consolidated outstanding issuance to opt for state supervision. That option requires the Stablecoin Certification Review Committee to approve the state's framework under a federal test of whether its rules are substantially similar to federal requirements.
a16z warned that differences between New York's final rule and the eventual federal requirements could lead the committee to deny New York's certification. Its letter cited 383 comments across two federal proceedings at the time: 55 on Treasury's proposal and 328 on the OCC's. The firm acknowledged that New York's draft already addresses some questions still under federal consideration. Among its provisions, issuers with at least $25 billion in outstanding payment stablecoins would have to maintain at least 0.5% of reserves as insured deposits or insured shares at an insured depository institution each business day, subject to a $500 million cap.
a16z argues that later federal changes could leave New York-regulated issuers facing conflicting requirements. Accordingly, the firm has asked NYDFS to issue a revised rule after the federal standards are final.
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