A T

Subject: Comment on Proposed Rule OCC-2026-0463 Regarding Uninsured National Trust Banks Issuing Stablecoins To the Office of the Comptroller of the Currency, I appreciate the opportunity to comment on proposed rule OCC-2026-0463 regarding uninsured national trust banks and stablecoin activities. As the OCC considers the framework for uninsured national trust banks that issue payment stablecoins, I encourage the agency to adopt strong transparency, governance, and accountability standards that preserve public confidence in the national banking system. Specifically, I respectfully recommend that the final rule require: Beneficial Ownership Transparency Public disclosure of the natural persons who ultimately own or control the institution. Disclosure of significant foreign investors and entities with substantial ownership interests. Clear identification of who receives economic benefits from reserve assets, including any interest or investment income generated by those reserves. Enhanced Review for Political and Foreign Influence Enhanced supervisory review when an applicant's ownership structure includes elected officials, immediate family members of elected officials, senior government officials, or investors associated with foreign governments or sovereign wealth interests. Such circumstances present heightened conflict-of-interest and public confidence concerns that warrant additional scrutiny beyond ordinary licensing review. Transparency Regarding Enforcement The proposed rule should clearly explain how any enforcement discretion, compliance safe harbors, or consultation requirements with the Department of the Treasury will operate in practice. The public should understand how these provisions will ensure consistent supervision and avoid the appearance that similarly situated institutions receive different treatment because of political influence or ownership structure. Reporting of Asset Freezes Stablecoin issuers should maintain auditable records whenever they freeze or restrict customer assets. Aggregate statistics regarding the frequency, legal basis, and duration of asset freezes should be reported publicly on a regular basis while protecting customer privacy. Finally, because the proposed rule specifically seeks input regarding uninsured national trust banks, I encourage the OCC to apply heightened governance, disclosure, and supervisory standards—not reduced requirements—to any institution issuing payment stablecoins. Robust transparency regarding ownership, reserve management, and supervisory oversight is essential for maintaining public trust and protecting the integrity of the banking system. Thank you for considering these comments. Respectfully,