Ripple Chief Legal Officer Stuart Alderoty and the National Cryptocurrency Association have urged the U.S. Treasury to protect stablecoin holders as it develops regulations under the GENIUS Act. Alderoty, who also serves as NCA president, said the framework should allow Americans to hold and transfer stablecoins without being forced through custodial intermediaries.
The comments, published on October 19 and 20, 2026, focus on three main areas: transition periods, stolen fund recovery, and self-custody.
Transition periods. The NCA wants the Treasury to establish time-limited windows allowing existing stablecoin holders to redeem, sell, or convert tokens before regulatory restrictions take effect. This includes situations where waivers expire or state certifications face denial or lapse, as well as the July 18, 2028 offer-and-sale deadline. During these periods, platforms should support transactions by existing holders without allowing new purchases.
Stolen asset recovery. The association urged clear rules so stolen stablecoins can be recovered and returned to victims under lawful orders. It argued that Treasury should leave no doubt that lawful orders do not automatically violate issuance restrictions.
Self-custody. Alderoty said software providers that do not control customer assets should remain distinct from custodial financial intermediaries. He also called for practical pathways allowing users to redeem, sell, or convert affected stablecoins if an issuer loses authorization or regulatory requirements change.
The NCA cited data showing that more than 67 million Americans hold cryptocurrency, while 87% of crypto holders use it for activities beyond ownership. It reported that 41% send money to family, 40% use crypto for shopping and payments, 49% want greater transparency from crypto companies, and 39% seek stronger government oversight and regulatory clarity.
The Treasury’s implementation process remains underway, meaning these recommendations represent industry input rather than finalized regulation. The next milestone will be how the Treasury incorporates self-custody, redemption protections, and asset-recovery provisions into its final stablecoin rules.
