The American Bankers Association is urging U.S. regulators to require anyone who buys or redeems a payment stablecoin directly with its issuer to open an account and complete a customer identification program, or CIP, before cashing out. The Blockchain Association accepts CIP for direct primary-market account customers but argues that an optional one-off redemption or a redemption routed through another regulated intermediary should not automatically make the underlying holder an issuer customer. The clash appears in comments on a June joint proposal from FinCEN, the OCC, the Federal Reserve, the FDIC and the NCUA implementing GENIUS Act CIP duties for permitted payment stablecoin issuers. The draft says direct issuance or redemption can establish an account, while token ownership alone or a third-party smart-contract interaction does not, and it expressly asks—without answering—whether a direct redemption by a holder with no prior issuer relationship creates an account. Circle and Paxos already limit eligible U.S. direct redemptions to verified account customers, illustrating existing controls without settling the federal floor. Banking groups have also pressed for broader secondary-market oversight, while crypto groups including the Blockchain Association, the DeFi Education Fund and the Solana Policy Institute urge regulators to keep identity checks tied to direct issuer relationships. No final rule has been issued; broader GENIUS Act limits on unlicensed issuance are set to begin January 18, 2027.