Comment from American Bankers Association (ABA)

Summary: The American Bankers Association (ABA) supports the proposed rule to establish AML/CFT and sanctions compliance requirements for permitted payment stablecoin issuers (PPSIs). The ABA advocates for specific refinements, including an examination framework that ensures parity across all PPSI categories, "deemed compliance" for PPSI subsidiaries of banks, and clear definitions for technical terms like "freeze" and "burn."