Metrika’s Letter to the Office of the Comptroller of the Currency (OCC) on the GENIUS Act

Metrika submitted a comment letter to the Office of the Comptroller of the Currency this week on the proposed rule implementing the GENIUS Act for stablecoin issuers.

Our focus: Operational Risk

Specifically, what it means to treat blockchain infrastructure as critical infrastructure, not just a settlement layer, but a source of real, continuous, and often under-appreciated risk.

The Proposed Rule gets a lot right. But there are gaps worth naming.

Stablecoin issuers rely on external, decentralized networks they do not control. Validator concentration, consensus instability, smart contract vulnerabilities, network congestion, these are not edge cases. They are the operating environment. And they require real-time monitoring, not periodic attestation.

We made four specific recommendations to the OCC:

1. 𝐔𝐧𝐬𝐚𝐟𝐞 𝐏𝐫𝐚𝐜𝐭𝐢𝐜𝐞𝐬: Define unsafe practices to explicitly include failures in blockchain-level operational risk management
2. 𝐑𝐞𝐬𝐞𝐫𝐯𝐞 𝐕𝐞𝐫𝐢𝐟𝐢𝐜𝐚𝐭𝐢𝐨𝐧: Require on-chain monitoring as part of reserve verification, not just reported figures
3. 𝐓𝐨𝐤𝐞𝐧𝐢𝐳𝐞𝐝 𝐂𝐨𝐥𝐥𝐚𝐭𝐞𝐫𝐚𝐥 𝐑𝐢𝐬𝐤𝐬: Treat tokenized collateral risks (smart contract execution, settlement finality) in haircut and collateral eligibility frameworks
4. 𝐑𝐞𝐝𝐞𝐦𝐩𝐭𝐢𝐨𝐧 𝐑𝐢𝐬𝐤 𝐅𝐫𝐚𝐦𝐞𝐰𝐨𝐫𝐤𝐬: Extend redemption risk frameworks to account for network performance conditions, not just liquidity

We are already part of how institutions meet the New York State Department of Financial Services BitLicense standard of what continuous, infrastructure-aware risk management actually looks like in practice. We think the same approach belongs at the federal level.

The GENIUS Act represents a meaningful moment for Stablecoin regulation in the US. Getting the operational risk standards right from the start matters.

Full comment letter can be found here: https://www.regulations.gov/comment/OCC-2025-0372-0119