In its November 6 filing, Coinbase called on regulators to interpret the law narrowly — focusing only on stablecoin issuers and avoiding unnecessary oversight of blockchain developers, validators, and open-source contributors. Chief Policy Officer Faryar Shirzad said in a post on X that the final rules must stick closely to the bill’s text, stressing that U.S. stablecoins need flexibility and competitiveness to maintain global dominance in payments and settlements.

Coinbase Chief Policy Officer Faryar Shirzad on X
Faryar Shirzad, Coinbase Chief Policy Officer, commented on X

Coinbase also asked the Treasury to clarify that the ban on paying interest should apply only to stablecoin issuers, not to exchanges offering rewards or loyalty programs. The company argued that stretching this rule would contradict what Congress intended when the law passed.

Stablecoins as Digital Cash

Coinbase proposed treating payment-focused stablecoins as cash equivalents for accounting and tax purposes. Since these tokens are fully backed and operate like real money, the company said they should be recognized in the same way. It urged the Treasury and IRS to take a simple, practical approach to taxation, helping both users and businesses comply without unnecessary bureaucracy.

Coinbase believes this would make digital payments more efficient while supporting transparency and compliance. The company also pushed back against claims that stablecoin adoption could drain deposits from U.S. banks, noting that most demand comes from overseas users seeking dollar access.

The GENIUS Act in Context

Signed by President Donald Trump in July 2025 after bipartisan approval, the GENIUS Act became the first federal framework for regulating U.S. dollar-backed stablecoins. It requires issuers to keep cash or liquid reserves, undergo annual audits, and comply with rules for foreign issuance. The Treasury is now reviewing public comments before finalizing its implementation roadmap.

Following the law’s passage, Coinbase shares rose 16%, as investors welcomed clearer regulatory rules. The company’s partnership with Circle (USDC) continues to be a major source of revenue, reinforcing its central role in the stablecoin market.

Globally, the GENIUS Act brings the U.S. in line with the EU’s MiCA regulation and Hong Kong’s new framework, signaling a growing international alignment on digital asset oversight. Meanwhile, the Bank of England is set to release its own stablecoin consultation on November 10, with Deputy Governor Sarah Breeden saying the U.K. aims to move just as fast as the U.S.

Coinbase’s response highlights how the GENIUS Act could shape the next phase of crypto regulation in the U.S. — striking a balance between innovation and accountability while keeping America at the forefront of financial technology.