The signal
On 21 August 2026, the Bank Policy Institute and The Clearing House Association backed proposed US customer identification rules for stablecoin issuers while seeking three clarifications. Their letter focuses on relationships created by secondary-market intermediaries, direct redemption of tokens, and the definitions of “customer” and “account”.
Why it matters
The proposal from FinCEN and four other regulators adapts familiar banking checks for permitted stablecoin issuers. The boundary is less clear when a token moves through a platform, self-hosted wallet or automated contract without a direct relationship with its issuer. An ambiguous rule could leave a gap or make two parties perform the same check.
What changes
The letter does not alter any obligation yet. It asks regulators to specify which actor actually establishes the customer relationship and how an issuer should handle a redemption request from someone who acquired tokens in the secondary market. The answer will shape procedures for US issuers, platforms and other intermediaries.
The caveat
BPI and TCH represent banking interests and are not public authorities. Their position supports customer checks but proposes an allocation that may limit the issuer’s direct burden. FinCEN’s text remains a proposal, and the final rule may accept, revise or reject these requests.
What to watch
The next evidence will be the final rule and its operational definitions of customer and account. Key tests include who verifies identity during direct redemption, what evidence an issuer may accept from an intermediary, and whether the agencies align this text with other GENIUS Act rules.