Billie Jean Turner
Billie TurnerSupportIndividual
Summary: Billie Jean Turner, a private citizen and bank account holder, supports the proposed rule's distinction between primary-market and secondary-market transactions. She requests that the agencies preserve this distinction, commit to a separate rulemaking process for any future expansion of requirements, and provide clear language in the preamble regarding excluded transaction categories.
July 28, 2026
Office of the Comptroller of the Currency
Financial Crimes Enforcement Network
Board of Governors of the Federal Reserve System
Federal Deposit Insurance Corporation
Re: Docket ID OCC-2026-0331 — Comment on the Proposed Customer Identification Program (CIP) Rule for Permitted Payment Stablecoin Issuers
To Whom It May Concern:
My name is Billie Jean Turner , and I am a member of the public and a bank account holder in Bend, Oregon. I am submitting this comment in response to the interagency notice of proposed rulemaking implementing Customer Identification Program requirements for Permitted Payment Stablecoin Issuers (PPSIs) under the GENIUS Act.
I understand the current proposal anchors CIP obligations to "formal" primary-market account relationships, and does not extend identity-verification requirements to secondary-market, peer-to-peer, or smart-contract-only transactions. I support keeping that distinction clear and explicit in the final rule.
I am writing to ask the agencies to:
1. Preserve the account-based anchor as drafted. The line between primary-market institutional activity and secondary-market retail activity should remain explicit in the final rule text, not left to future guidance or informal interpretation.
2. Commit to a separate rulemaking, with its own public comment period, before any future expansion of CIP obligations to secondary-market or retail stablecoin activity. If the scope of this rule changes in the future, the public should have the same opportunity to comment that this docket currently provides.
3. Clarify, in the final rule's preamble, exactly which categories of transaction are excluded — so that ordinary account holders and everyday users of stablecoins have a clear, plain-language answer to "does this rule apply to me," rather than having to interpret legal text designed for institutions.
I appreciate the opportunity to comment and ask that this letter be included in the public record for Docket OCC-2026-0331.
Respectfully,
Billie Jean Turner
Kirkland, WA