Ripple's Chief Legal Officer (CLO) Stuart Alderoty, on behalf of the National Cryptocurrency Association (NCA), submitted a comment letter to the U.S. Department of the Treasury regarding Rule 3 of the GENIUS Act, aiming to end the uncertainty surrounding stablecoin regulation. The document notes that the crypto industry accepts the requirement for stablecoin issuers to hold 100% reserves, while also proposing a practical framework to protect retail holders from having their funds trapped during regulatory changes. This framework includes establishing a "safe harbor" mechanism, allowing users to redeem, sell, or convert stablecoins within a temporary window, and creating legal mechanisms for the return of stolen assets. Additionally, the NCA clearly distinguishes between custodial services and software developers, emphasizing that peer-to-peer (P2P) transfers between individuals and self-custody operations should remain free from regulatory restrictions.