Steven Singleton

Submitted to Docket OCC-2026-0463 on the OCC's proposed anti-money-laundering, countering-the-financing-of-terrorism, and sanctions rule for permitted payment stablecoin issuers (FR Doc. 2026-12692, 91 FR 37840). This comment supports the coordination the rule is designed to achieve and offers six refinements, each a clarification the OCC can make on the record without disturbing the rule's design. The full comment is attached. The rule is, in substance, a coordination instrument: it draws its obligations from a still-proposed FinCEN/OFAC rule and reserves three levers for itself — an enforcement safe harbor, a FinCEN consultation step, and a channel for sharing confidential OCC information. The requests: 1. Define "effective program" and "significant or systemic failure," and settle the underlying duty on a single verb — preferably "maintain," the formulation used government-wide. 2. State how the rule will respond if the incorporated FinCEN/OFAC rule changes, and whether the Section 15.13(c) cross-reference is to that rule as adopted or as amended. 3. Identify where the full costs and benefits of the incorporated obligations are assessed for the public; the $0 figure reflects only this rule's marginal additions. 4. Put the privilege non-waiver protection on explicit footing rather than the "any other agency" catch-all in 12 U.S.C. 1821(t), and state the OCC's reading of that statute as applied to FinCEN. 5. Give the 30-day consultation notice a stated standard for when it may be shortened. 6. Weigh the provisions in the aggregate, not only individually, and state whether the net movement toward lighter scrutiny is intended. Because the FinCEN/OFAC rule's own comment period closed on June 9, 2026 — before this docket opened — the comment also asks the OCC to treat concerns about the incorporated substance, including data collection and retention, as properly before it in this proceeding through the cross-reference.