The National Cryptocurrency Association (NCA) has called on the U.S. Treasury Department to adopt safeguards for stablecoin holders as the agency develops regulations under the GENIUS Act, the federal statute establishing a regulatory framework for payment stablecoins. In its comments, the nonprofit asked regulators to provide transition periods when stablecoins' legal status changes, to establish clear routes for recovering stolen funds, and to protect self-custody and peer-to-peer transfers. The submission was filed as public comment in the Treasury's rulemaking process, through which the agency gathers stakeholder input before finalizing the rules that will put the statute's framework into operation.

The association announced its recommendations in a post on X.

NCA Seeks Transition Periods for Stablecoin Holders

Existing holders should retain sufficient time to redeem, sell, or convert their tokens when regulatory changes restrict a stablecoin's availability, the NCA said. Its recommendations address several provisions, including the Act's effective date, temporary waivers, state certification decisions, and the July 18, 2028, offer-and-sale deadline.

The group warned that holders could lose access to their tokens if platforms stop supporting a stablecoin the moment a prohibition takes effect. It urged the Treasury to establish time-limited transition windows before restrictions begin, including when waivers expire or when state certifications face denial or lapse. During those windows, platforms should continue to support transactions by existing holders without allowing new purchases.

The NCA also asked the Treasury to clarify that redemptions, conversions, required notices, custody, and technical support would not automatically violate the restrictions.

Stolen Funds and Lawful Orders

The comment letter also addressed the recovery of stolen stablecoins through lawful orders. Treasury's proposal excludes transfers required by orders from its definition of issuance and allows issuers to reissue stablecoins to comply with them.

The association wants the rules to leave no doubt that stolen funds can be recovered and returned to victims under lawful authority. Its submission focused on consumer protections rather than the technical details of issuer compliance.

Self-Custody and Consumer Trust

The NCA urged the Treasury to protect self-custody and peer-to-peer transfers while establishing clear regulatory boundaries. It cited research showing that more than 67 million Americans hold cryptocurrency and that 87% of crypto holders use it for activities beyond ownership.

According to the association, 41% send money to family, while 40% use crypto for shopping and payments. It also reported that 49% of surveyed holders want greater transparency from crypto companies, while 39% seek stronger government oversight and regulatory clarity — findings the association said reflect broad public demand for clearer rules. That usage, spanning remittances and everyday payments, is the backdrop the association invoked in arguing that holder protections matter well beyond active traders.

Stuart Alderoty, president of the National Cryptocurrency Association, said Treasury's rules must prevent Americans from being stranded with stablecoins after regulatory changes. He also called for pathways to recover stolen funds and to preserve the option of self-custody. With the comment now filed, attention turns to how Treasury weighs these recommendations as it moves from proposal to final rules, with statutory milestones such as the July 18, 2028, offer-and-sale deadline ahead.