Anchorage Digital Bank has filed a formal comment letter arguing that two mechanisms in the Office of the Comptroller of the Currency's proposed stablecoin rules could manufacture the very crises they are designed to prevent.

The OCC's proposal, published in the Federal Register on March 2, 2026, would implement the GENIUS Act across 376 pages and 211 questions. Rachel Anderika, chief operating officer and chief trust officer of Anchorage Digital Bank — the first federally chartered digital asset bank in the United States — wrote the critique, drawing on a decade as an OCC bank examiner.

"This is what rigorous rulemaking looks like," Anderika said of the overall proposal, while cautioning that specific design choices would backfire under stress. The central organizing principle — redemption certainty — is correct, she argued. The mechanics are not.

Why does the seven-day redemption gate worry issuers?

The draft rule would automatically pause redemptions for any issuer facing withdrawals exceeding 10% of outstanding supply within a 24-hour window. The intent is to give issuers time to liquidate assets under stress. Anderika argues the effect would be the opposite.

She points to the Securities and Exchange Commission's experience with money market funds. When regulators tied a publicly reported trigger to an automatic restriction, sophisticated investors redeemed ahead of the gate, accelerating the outflows the rule was meant to slow. The SEC eliminated that mechanism in 2023.

Stablecoin holders have an advantage money market investors never had: real-time, on-chain visibility into aggregate flows. "An automatic tripwire in a rule that the market can observe and anticipate is a countdown clock, not a safeguard," Anderika wrote.

Does the 10% bank deposit requirement repeat the SVB mistake?

The proposal would require issuers to hold 10% of reserves as deposits at FDIC-insured banks, targeting daily liquidity. At scale, Anderika argues, the requirement concentrates reserves in uninsured bank deposits.

The precedent is concrete. In March 2023, USDC temporarily lost its dollar peg because its reserves included more than $3 billion in uninsured deposits at Silicon Valley Bank. As drafted, the rule would require large issuers to hold more in uninsured deposits than USDC held at SVB at the time of that failure.

Anchorage's preferred alternative: tokenized government money market funds, which it uses as its primary reserve asset. These offer same-day or next-day liquidity backed by Treasury securities, carry no single-institution credit risk, and have historically seen inflows — not outflows — during periods of stress.

What framework does Anchorage propose instead?

Anderika's letter recommends a principles-based approach:

• Issuers must demonstrate the ability to monetize a defined percentage of reserves overnight.
• One-to-one backing must hold under significant stress.
• Each issuer shows how it meets the standard, subject to supervisory review.

The OCC has run individualized, risk-based examinations of national banks for more than 160 years, she noted, and is well practiced at this supervisory model.

The letter also raises a structural point about reserve custody. Most existing issuers hold reserves on their own balance sheets, creating a creditor relationship: in an insolvency, stablecoin holders wait in line alongside other claimants. Anchorage's OCC-chartered bank instead holds reserves for each of its stablecoins in a separate legal trust, siloed from corporate assets. Under that structure, reserves transfer to a successor trustee and redemptions continue uninterrupted. The GENIUS Act permits this model; Anderika argues the final rule should state clearly that it accommodates it.

Treasury Secretary Scott Bessent has framed the GENIUS Act as a tool for extending dollar dominance, a goal Anderika endorses — provided U.S. rules make American issuers the most trusted option globally. That trust, she writes, is earned "the day redemptions spike, reserves are scrutinized, and holders decide whether to wait or run, and the rules hold."

The OCC's comment process remains the open window for refining the framework before the final rule locks in the redemption gate and deposit requirements that issuers say invite the runs they exist to prevent.