Comment from Independent Community Bankers of America (ICBA)

Summary: The Independent Community Bankers of America (ICBA) supports the proposed rule to treat permitted payment stablecoin issuers as financial institutions subject to Bank Secrecy Act AML/CFT and sanctions compliance requirements. They argue that stablecoin issuers must be held to standards at least as rigorous as those for community banks to prevent regulatory arbitrage and mitigate risks associated with illicit finance and sanctions evasion.