Michael Beggs

Office of the Comptroller of the Currency (OCC) Re: Public Comment on Uninsured National Trust Charters for Stablecoin Issuers (Docket OCC-2026-0463) The OCC should deny national trust bank charters and stablecoin issuers tied to sitting elected officials, foreign governments, and offshore entities because of the corruption such association will encourage. If the OCC does permit such companies to operate as uninsured banks, then the OCC must ensure the U.S. banking system is protected by implementing the strongest transparency and oversight controls for such companies. To identify those companies requiring the strongest oversight, the rules must require public disclosure of the owners behind every federally chartered coin company. Any uninsured banks must be required to publicly name the people who own it and who will be profiting from it. Furthermore, any foreign investors, and anyone who keeps the interest the reserve earns, must be publicly identified before it can qualify under the rule. That is a minimum requirement so the agency can effectively identify the risks that this rule is intending to police. Such foreign involvement is proved by the United Arab Emirates having stakes in such a company. They must face the strictest review and compliance. Likewise, freeze reporting must be required. Such coins are required to have a mechanism to freeze consumer funds. The OCC must require a written record and publicized numbers every time such a mechanism is used. And the enforcement carve-out for issuers with "effective compliance programs," must be clarified to deny routing enforcement through the Treasury. Otherwise, such a structure would provide protection for politically connected banks and those with foreign co-owners. Explain how that carve-out will be defined to prevent such political corruption.