Stuart Alderoty filed comments with the US Treasury urging protections that keep stablecoin holders from getting stranded
Ripple’s top lawyer wants crypto users to have the kind of safety net most bank customers take for granted. Chief Legal Officer Stuart Alderoty says people holding digital assets need clear protective rules, and he points to the GENIUS Act as the model.
The timing matters. The law’s new stablecoin rules are expected to begin taking effect on January 18, 2027, and the window for shaping the details has now closed.
What Alderoty actually asked for
On October 19, 2026, Alderoty submitted formal comments to the US Treasury. He filed them on behalf of the National Cryptocurrency Association (NCA), not just Ripple.
That date was the final day of the public comment period on the GENIUS Act.
The GENIUS Act sets up a framework for payment stablecoins. Those are digital tokens built to hold a steady value, typically pegged to a currency like the dollar.
One of the law’s central features is a 100% reserve requirement for those stablecoins. Alderoty’s comments backed that requirement.
Reserves were only part of the pitch. Alderoty’s bigger focus was what happens to ordinary holders when something goes wrong with the company that issued their coins.
His proposed safeguards include:
- Safe-harbor redemption periods, giving holders time to cash out if an issuer loses its authorization or runs into compliance trouble.
- Recovery pathways for stolen assets, so theft victims have a route to getting funds back.
- Protection for self-custody and peer-to-peer transfers, preserving the ability to hold your own coins and send them directly to others.
The common thread is simple. A regulatory problem at the issuer level shouldn’t leave the person holding the token locked out of their money.
Software versus custodians
Alderoty also stressed a distinction that sounds technical but has real consequences. He argued that software providers should be kept separate from custodial intermediaries.
A custodian actually holds your assets, the way a bank holds your deposits. A software provider, like a wallet app, may just give you the tools to manage assets you control yourself.
Alderoty’s point was that keeping this line clear helps consumers keep control of their digital assets during regulatory transitions.
How we got here
The GENIUS Act passed in 2025. It ranks among the most consequential pieces of US crypto legislation so far, particularly for the stablecoin sector.
Passing a law, though, is the opening act. The Treasury still has to write the rules that turn broad statutory language into specific obligations, and public comment is how industry groups, consumer advocates and others get a say.
The NCA angle is worth noting too. Filing through an association rather than as a single company signals an attempt to speak for a wider set of users, not just one firm’s business interests.
What this means for stablecoin holders and the industry
For everyday users, the most practical piece of Alderoty’s filing is the safe-harbor idea. Stablecoins are only as useful as your ability to redeem them, and a sudden issuer shutdown is exactly the scenario where that ability gets tested.
The self-custody and peer-to-peer protections speak to a long-running tension in crypto policy. Regulators tend to prefer activity flowing through identifiable intermediaries, while many users value the ability to hold and move assets on their own.
For issuers, the 100% reserve requirement is the headline obligation. Full backing raises the cost of running a stablecoin, but it also gives compliant issuers a clean story to tell users and institutions about why their token holds its value.
The key date to watch is January 18, 2027, when the new rules are expected to start applying. Between now and then, the Treasury will work through the submitted comments and settle the details.
