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Coalition Letter to Congress Seeking Legislative Fix to GENIUS Act Provision

August 15, 2025

NCLC joined the American Bankers Association, Americans for Financial Reform, Conference of State Bank Supervisors, Independent Community Bankers of America, Money Transmitter Regulators Association, and National Conference of State Legislatures urging Congress to strike Section 16(d) of the recently enacted GENIUS Act. Section 16(d) allows any state-chartered uninsured depository institution with a stablecoin subsidiary to…

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Letter to FHFA on Cryptocurrency in Mortgage Lending

August 14, 2025

The National Consumer Law Center (on behalf of its low-income clients) and Consumer Federation of America, in a letter to Federal Housing Finance Agency Director William Pulte, strongly oppose the inclusion of crypto assets in the underwriting of federally insured mortgages. This proposal will expose taxpayers to increased risk of losses, open the door to…

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Comment Letter to OCC in Opposition to First National Digital Currency Bank Charter Application

August 12, 2025

NCLC joined various consumer organizations in a letter opposing the application by Circle Internet Group, Inc. (“Circle”) for a national trust bank charter under the name First National Digital Currency Bank, N.A. (“FNDCB”). Circle is a stablecoin issuer seeking to obtain a national bank charter. Granting a national trust bank charter to any stablecoin issuer…

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Letter Opposing CLARITY Act

July 16, 2025

NCLC joined 82 investor, consumer and other advocacy organizations opposing the CLARITY ACT, H.R. 3633, which legitimizes risky and exploitative crypto industry practices. The bill seeks to create a “market structure” and regulatory regime for crypto platforms and crypto traders, but the bill weakens the enforcement powers of federal financial regulators, undermines state regulators’ ability…

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Comment to CFPB's Proposed Interpretative Rule on Electronic Fund Transfers Through Accounts Established Primarily for Personal, Family, or Household Purposes Using Emerging Payment Mechanisms

March 28, 2025

Consumers need clarity about the application of the EFTA and Regulation E to emerging payment mechanisms. More specifically, consumers utilizing crypto-assets as payments and holding funds in accounts through gaming platforms, credit card rewards, and similar devices need the protection of the EFTA— its error resolution procedures, limits on consumer liability for unauthorized EFTs, and…

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Letter Opposing the GENIUS Act

February 28, 2025

NCLC joined a letter from several consumer and investor protection organizations opposing the GENIUS Act and the STABLE Act, as introduced in Congress this session. Stablecoins used either to facilitate investment activity on crypto exchanges or as tools for payments present a host of risks – run risks, contagion and financial stability risk, custody risks,…

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Letter Opposing HJ Resolution 109 Rescinding the Securities and Exchange Commission's Staff Accounting Bulletin (SAB) 121

May 17, 2024

HJ Resolution 109 is a Congressional Review Act resolution to repeal SEC Accounting Bulletin 121 (SAB 121). The bulletin requires that financial institutions (including banks and exchanges) count crypto assets as liabilities on their balance sheets (to account for their risk and volatility) and to make certain disclosures regarding those risks – which the SEC…

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Opposition Letter to H.R. 4763, the Financial Innovation & Technology for the 21st Century Act

July 13, 2023

NCLC signed-on to a letter submitted to the House Committee on Financial Services and House Committee on Agriculture opposing proposed crypto legislation.

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Comments to FDIC Regarding False Advertising, Misrepresentation of Insured Status, and Misuse of the FDIC's Name or Logo

April 6, 2023

The National Consumer Law Center (on behalf of its low-income clients), Americans for Financial Reform Education Reform Fund, Consumer Reports, Student Borrower Protection Center, Public Justice Center, Public Good Law Center, U.S. PIRG, Consumer Federation of America, and Better Markets submitted comments regarding the Federal Deposit Insurance Corporation’s (FDIC) recent proposed changes to part 328…

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Coalition Letter to U.S. Senate Committee on Agriculture Regarding Investor Choice and Digital Commodities Legislation

December 9, 2022

As organizations that share a commitment to investor choice, we write to express strong concern that the Digital Commodities Consumer Protection Act (S. 4760), as currently drafted, does not contemplate any safeguards with respect to injured investors’ ability to hold digital commodity issuers, brokers, and affiliated entities, accountable for misconduct. Decades of experience with the…

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Comments Regarding the Request for Comment on Digital-asset-related Illicit Finance & National Security Risks

November 3, 2022

Joint Comments to the U.S. Treasury re: the Request for Comment on Digital-asset-related Illicit Finance & National Security Risks.

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Comments to Treasury on Ensuring Responsible Development of Digital Assets

October 3, 2022

This request for comments covers two different sets of digital assets: cryptocurrencies, including stablecoins, and central bank digital currencies. We see little to no legitimate use for cryptocurrencies and few, if any, potential benefits that are not heavily outweighed by the high degree of risk, harm, and evasion of consumer protection laws.

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