The Blockchain Association has urged five U.S. federal agencies to confirm that customer identification requirements for permitted payment stablecoin issuers under the GENIUS Act cover only direct issuer-customer relationships, not independent peer-to-peer or other secondary-market transfers. In comments filed by the Aug. 21 deadline and summarized on Aug. 24, the group supported primary-market identity checks for activities such as issuing, redeeming, converting, repurchasing or providing custody, while opposing extension of those duties to downstream transactions the issuer does not intermediate. The joint proposal from FinCEN, the OCC, the Federal Reserve, the FDIC and the National Credit Union Administration would require bank-style collection of names, addresses, birth or formation dates and identification numbers, with records generally retained for five years. Agencies estimated that about 99% of stablecoin activity occurs in secondary markets where issuers have limited ability to identify users. Separately, the Bank Policy Institute has pressed for identity-verification obligations on exchanges and DeFi venues handling secondary-market volume. Final customer identification rules would take effect 12 months after issuance, as the GENIUS Act’s broader restrictions on unlicensed U.S. payment stablecoin issuance are set to begin on Jan. 18, 2027.