Overview
- Treasury’s Section 3 proposal, which closed for comment on October 19, 2026, received roughly 123 submissions and prompted major filings from the Blockchain Association and the National Cryptocurrency Association.
- The Blockchain Association asked Treasury to narrow the definition of “Digital Asset Service Provider” so validators, self-custody software, and firms that only trade their own inventory are not swept into regulation.
- That group also urged limiting criminal and civil exposure to cases of actual knowledge and substantial assistance so ordinary secondary-market trading and market-making are not criminalized.
- The NCA, led by Stuart Alderoty, asked for explicit transition protections for holders, including temporary windows to redeem, sell, or convert tokens and clear procedures to recover stolen stablecoins under court orders.
- Final policy must still align across agencies because the Federal Reserve has separate reserve, capital, and custody proposals, and Treasury is reviewing comments before issuing rules tied to phased effective dates in January 2027 and July 2028.