Comment from VeloxVFX LLC
VeloxVFX LLCSupportBusiness
Summary: VeloxVFX LLC, a company providing architecture-oriented concepts, supports the proposed rule but argues that Customer Identification Program (CIP) obligations should be tied to specific, defined customer-relationship states rather than mere possession of a stablecoin or secondary-market activity. They advocate for a "lifecycle-separated" framework to improve supervisory readability, preserve institutional boundaries, and clarify responsibilities between issuers and intermediaries.
VeloxVFX LLC respectfully submits the attached comment in response to the joint proposed rule entitled “Permitted Payment Stablecoin Issuer Customer Identification Program.”
The attached PDF contains VeloxVFX LLC’s complete informational, architecture-oriented public comment, including responses to the agencies’ questions, relationship-state classification analysis, proposed clarifying principles, and supporting appendices.
The attached PDF is incorporated into this submission in its entirety and is respectfully submitted for consideration as part of the public rulemaking record.