The OCC is fixing reporting schemas, data formats, and attestation cadence for stablecoin issuers under its jurisdiction—decisions that will shape compliance infrastructure and interoperability assumptions for years. The comment window is the inflection point to influence what data fields are required, how reserve composition is verified, and whether formats align with on-chain practices already in use. The Ethereum community can supply working examples of how reserves are currently attested on-chain, educate the agency on machine-verifiable data models, and advocate for formats that do not lock in assumptions incompatible with decentralized infrastructure.
EEA should coordinate a member coalition comment on the OCC proposed forms, highlighting on-chain reserve attestation practices, standardized data schemas for stablecoin reporting (e.g., ERC-20 metadata, attestation standards), and interoperability implications. Advise members who are regulated stablecoin issuers to submit individual comments and engage OCC directly during the comment period.
