DDCP Foundation, Inc. 3
DDCP Foundation, Inc.SupportAdvocacy
Summary: The DDCP Foundation is submitting a supplementary comment on behalf of DDUSD, LLC, a prospective federal qualified payment stablecoin issuer. They argue that DDUSD's co-signature architecture, which operates on identified persons rather than wallet addresses, inherently satisfies the "reasonable particularity" standard of the GENIUS Act by preventing the "structural execution gap" found in centralized administrative key designs.
Please find attached second supplementary comment from DDCP Foundation. Initial comment ID OCC-2025-0372-0257. First supplementary comment ID OCC-2025-0372-0349.