Circle Urges SEC to Treat Payment Stablecoins as Cash

Circle submitted a comment letter to the SEC on its proposed Regulation Crypto Assets, which would create a tailored framework for crypto-asset offerings. Circle backed the proposal's goal of a clear, technology-neutral approach to onchain capital formation while arguing the rules should operate consistently with the GENIUS Act.

• Circle asks the SEC to clarify that GENIUS-compliant payment stablecoins can be used for consideration and settlement in onchain capital formation, and that qualifying stablecoins constitute "cash" under proposed Rule 302(b)
• The letter recommends cutting the 2% broker-dealer haircut to zero for GENIUS-compliant payment stablecoins, subject to objective safeguards
• Circle also seeks clarification that post-launch technical services — like maintaining a known validator set — don't constitute essential managerial efforts, plus a safe harbor for technical roadmaps
• The comments echo Circle's framing of stablecoins as "the cash leg of the tokenized economy"