Circle has asked the U.S. Securities and Exchange Commission to clarify how qualifying payment stablecoins should be treated under proposed crypto-asset rules, while separately publishing a scheduled wind-down of legacy cross-chain infrastructure affecting Noble USDC holders.
The company’s comment letter, submitted on October 20 and summarized on October 28, requests coordination between the SEC’s proposed Regulation Crypto Assets and the GENIUS Act. Circle wants qualifying payment stablecoins recognized as cash under proposed Rule 302(b) and seeks a reduction in the broker-dealer haircut from 2% to zero, subject to safeguards. The letter also asks for clarity on how technical services performed after a blockchain network becomes functional should be treated under securities law.
These are policy requests from an interested market participant, not a final Commission decision. A regulatory haircut affects balance-sheet economics, so the proposed change could reduce intermediary costs if adopted, but the final rule wording may differ materially from Circle’s preferred approach.
On the operational side, Circle’s legacy CCTP V1 deprecation schedule began reducing burn limits on October 31, ahead of a general legacy-contract pause on December 1. For Noble, a separate notice sets January 12, 2027 as the pause date for Noble’s USDC contract and remaining CCTP routes. New Noble minting was scheduled to stop on October 13, and Noble will not receive CCTP V2 support.
Circle warns that after December 1, Noble exits may be limited to destinations still supporting V1. The January 12 date does not guarantee every route remains open until then. Remaining Noble balances will be snapshotted on that date, with a manual redemption process beginning the following day, subject to eligibility and compliance requirements.
For integrators and holders, the key task is to distinguish the general legacy deadline from the Noble-specific deadline, verify current route status, and account for transfers already in progress. A Cosmos community-pool migration proposal describes a planned move from Noble-issued to Injective-issued USDC, though publication alone does not confirm completion. The transition highlights that blockchain availability and issuer support have separate lifecycles, and that a token bearing the same ticker on one chain is not automatically interchangeable with versions on another network.
