Public Record Journal
The VeloxVFX LLC Public Record Journal indexes publicly available government submissions, published public comments, supplemental submissions, regulatory references, and related materials associated with proceedings before U.S. federal agencies.
Each entry preserves the publicly available chronology, subject matter, and status of the underlying proceeding while providing standardized references—including agency, docket, comment identifier, tracking number (when publicly available), publication date, and related materials—to facilitate independent verification through official government records.
The Journal documents evolving public discussions concerning lifecycle-separated architecture, interoperability, supervisory readability, operational continuity, transaction-state representation, audit-oriented traceability, institutional-boundary preservation, implementation governance, regulatory modernization, and related infrastructure topics across multiple regulatory proceedings.
Entries are organized by agency, rulemaking, and publication chronology to help readers independently follow the progression of publicly available regulatory discussions over time.
Public Record Notice
This Journal is provided solely as an informational, historical, educational, and public-record resource.
Publication of any public comment, supplemental submission, regulatory reference, or related material does not indicate or imply that any governmental agency has adopted, endorsed, approved, implemented, integrated, relied upon, accepted, or otherwise supported any framework, recommendation, terminology, architecture, interpretation, or analytical approach presented by VeloxVFX LLC.
Likewise, references to agency proceedings, rulemakings, public comments, or regulatory developments do not establish or imply collaboration, sponsorship, procurement, licensing, certification, governmental affiliation, institutional reliance, or any other official relationship between VeloxVFX LLC and any governmental agency, regulated institution, or other organization.
VeloxVFX LLC does not perform regulated financial activities or exercise governmental authority through these materials. All legally operative classifications, regulatory interpretations, supervisory determinations, approvals, examinations, enforcement actions, implementation decisions, and exercises of statutory authority remain exclusively with the appropriate governmental agencies and other independently authorized institutions under applicable law.
Official government records remain the authoritative source for every proceeding referenced within this Journal.
Federal Public Record
View VeloxVFX LLC public submissions across federal agency dockets www.regulations.gov
View VeloxVFX Filing on FDIC.gov
View VeloxVFX Filing on FederalReserve.gov
Federal Reserve
Federal Reserve
Proposed Third-Party Risk Management Guide for Traditional Community Banking Organizations
September 16, 2026
Federal Reserve Docket R-1880
Public Submission
VeloxVFX LLC, Eyad Haddadin (PDF)
Posted | September 16, 2026
Proposal: OP-1880
ID: FR-2026-0030-01-C04
Subject
Federal Reserve OP-1880 — proportional third-party risk management; community-bank operational clarity; third-party relationship states; provider dependency; contract and performance distinctions; deposit-placement networks; reviewable changes; and preservation of institutional and supervisory responsibility.
Summary
VeloxVFX LLC submitted an independent, technology-neutral architecture and information-governance comment concerning the Federal Reserve’s proposed Third-Party Risk Management Guide for Traditional Community Banking Organizations.
The submission addresses how community banking organizations may preserve readable third-party relationship states across due diligence, contracting, institutional approval, activation, monitoring, material change, exception, remediation, transition, and termination.
The comment further addresses provider dependency, differences between contractual terms and actual performance, deposit-placement networks, proportional reviewability, and the use of technology to support oversight without transferring institutional judgment, risk acceptance, compliance responsibility, or Federal Reserve supervisory authority.
VELOXVFX LLC • Public Comments
Federal Reserve
Regulatory Modernization and Relief for Mutual Holding Companies
September 9, 2026
Federal Reserve Docket R-1895
Public Submission
VeloxVFX LLC, Eyad G. Haddadin (PDF)
Posted | September 09, 2026
Proposal: R-1895
ID: FR-2026-0027-01-C03
Subject
Federal Reserve R-1895 — technology-neutral communications; receipt-state clarity; institutional record continuity; charter and bylaw version governance; and preservation of institutional and regulatory authority.
Summary
VeloxVFX LLC submitted a targeted public comment addressing selected Questions 21–26 of the Federal Reserve proposal. The comment discusses communication and receipt-state clarity, continuity of institutional records, charter and bylaw version governance, and preservation of institutional and regulatory authority.
VELOXVFX LLC • Public Comments
Federal Reserve
Permitted Payment Stablecoin Issuer Customer Identification Program
August 17, 2026
Federal Reserve Docket R-1885
Public Submission
VeloxVFX LLC, Ed Haddadin (PDF)
Posted | August 17, 2026
Proposal: R-1885
ID: FR-2026-0005-01-C06
Subject
Federal Reserve R-1885 — customer-identification and relationship-state clarity; direct-redemption and secondary-market boundaries; reliance arrangements; verification and exception records; and examination readability.
Summary
VeloxVFX LLC submitted a supplemental public comment addressing customer-identification and relationship-state clarity for permitted payment stablecoin issuers. The filing supplements the earlier interagency comment and discusses direct-redemption interactions, secondary-market activity, reliance arrangements, verification records, exceptions, and examination readability.
The filing supplements — and does not replace — VeloxVFX LLC's June 24, 2026 unified interagency comment publicly posted as FINCEN-2026-0101-0002.
The supplemental submission presents an informational and architecture-oriented perspective concerning:
relationship-status representation across the customer lifecycle;
direct-redemption interactions and their distinction from broader customer relationships;
verification-procedure-status evidence;
secondary-market activity and customer-relationship boundaries;
reliance arrangements and institutional attribution;
exception, escalation, remediation, and closure records;
examination readability and evidence continuity; and
preservation of agency authority and institutional responsibility.
The comment emphasizes that possession or transfer of a payment stablecoin, association with a wallet address, interaction with a smart contract, or participation in secondary-market activity should not, standing alone, conclusively establish a direct customer or account relationship with a permitted payment stablecoin issuer.
The submission further discusses how lifecycle-separated records may improve the readability of relationship, verification, reliance, exception, redemption, and evidentiary information available for authorized institutional review while preserving the distinction between informational records and legally operative determinations.
VELOXVFX LLC • Public Comments
Federal Reserve
Anti-Money Laundering and Countering the Financing of Terrorism Programs
July 13, 2026
Federal Reserve Docket R-1835
Public Submission
Posted | July 13, 2026
Proposal: R-1835
ID: FR-0000-0133-02-C09
Subject
Federal Reserve R-1835 — AML/CFT program governance; program-condition readability; evidence continuity; independent testing and remediation records; supervisory review; and audit-oriented traceability.
Summary
VeloxVFX LLC submitted a public comment addressing how lifecycle-separated records may improve the continuity, documentation, and reviewability of AML/CFT program information. The comment discusses risk-based governance, evidence continuity, independent testing, remediation records, and supervisory readability.
The submission presents an informational and architecture-oriented perspective concerning:
program-condition readability;
evidence continuity and documentation;
risk-based program governance;
independent testing and remediation-state documentation;
supervisory review and audit-oriented traceability;
structured compliance-state representation; and
preservation of institutional boundaries and legally authorized responsibilities.
The comment emphasizes that architecture may improve the organization, readability, continuity, documentation, and review of compliance information without replacing institutional governance, supervisory judgment, legal interpretation, or human decision-making where required by law.
VELOXVFX LLC • Public Comments
Federal Reserve System
Federal Reserve Policy on Payment Account Risk and Guidelines for Evaluating Account and Services Requests
July 01, 2026
Federal Reserve Docket R-1878
Public Submission
Posted | July 01, 2026
Proposal: OP-1878
ID: FR-2026-0013-01-C07
Subject
Federal Reserve OP-1878 — Payment Account governance; Payment System Risk policy; account-access review; operational safeguards; supervisory readability; lifecycle-separated payment, settlement, liquidity, exception, and audit states; illicit-finance safeguards; and institutional-boundary preservation.
Summary
VeloxVFX LLC submitted a public comment addressing the Federal Reserve’s proposed Payment Account framework, Payment System Risk policy, and Guidelines for Evaluating Account and Services Requests.
The filing addresses:
• limited-purpose Payment Account governance and account-access review;
• payment-system risk throughout the operational lifecycle;
• payment, settlement, liquidity, authorization, exception, reconciliation, and audit-state visibility;
• operational resilience, automated controls, and supervisory readability;
• illicit-finance safeguards and institutions that may not be federally insured; and
• separation among informational representation, financial execution, supervision, and monetary authority.
The comment also responds to concerns raised by Governors Michael S. Barr and Lisa D. Cook regarding responsible innovation, illicit-finance risk, supervisory visibility, operational governance, and preservation of institutional responsibility.
VELOXVFX LLC • Public Comments
Federal Reserve System
Regulation A: Extensions of Credit by Federal Reserve Banks
July 01, 2026
Federal Reserve Docket R-1892
Public Submission
Posted | July 01, 2026
Proposal: R-1892
ID: FR-2026-0014-02-C03
Subject
Federal Reserve R-1892 — Regulation A; Payment Account credit eligibility; primary, secondary, and seasonal credit; discount-window access; operational separation; and preservation of Federal Reserve lending authority.
Summary
VeloxVFX LLC submitted a public comment supporting clear separation between limited-purpose Payment Accounts and Federal Reserve credit facilities. The comment addresses credit eligibility, discount-window integrity, consistent implementation, and payment-system modernization without expanding borrowing relationships or Federal Reserve lending authority.
VELOXVFX LLC • Public Comments
Federal Reserve System
Regulation D: Reserve Requirements of Depository Institutions
July 01, 2026
Federal Reserve Docket R-1893
Public Submission
Posted | July 01, 2026
Proposal: R-1893
ID: FR-2026-0015-01-C02
Subject
Federal Reserve R-1893 — Regulation D; Payment Account and reserve-account separation; reserve balances; interest treatment; monetary neutrality; operational payment infrastructure; and preservation of statutory and institutional authority.
Summary
VeloxVFX LLC submitted a public comment supporting clear separation between limited-purpose Payment Accounts and reserve-account relationships. The comment addresses reserve balances, non-interest-bearing treatment, monetary neutrality, consistent implementation, and payment-system modernization without altering reserve policy or Federal Reserve authority.
VELOXVFX LLC • Public Comments
Historical Foundation
Intermediary Participation in the FedNow® Service and Amendments to Regulation J
July 01, 2026
Federal Reserve Docket R-1891
Public Submission
Posted | April 24, 2026
Proposal: R-1891
ID: FR-2026-0011-01-C15
Historical Attribution
The Federal Reserve public record identifies the submitter as Anonymous. VeloxVFX LLC includes this filing in its historical chronology based on retained submission records connecting the April 24, 2026 comment to the company’s earlier March 19, 2026 structural clarification.
This attribution is made by VeloxVFX LLC for historical-record purposes. The Federal Reserve docket itself does not identify VeloxVFX LLC as the submitter.
Subject
Federal Reserve R-1891 — intermediary participation in the FedNow® Service; amendments to Regulation J; authorization and participation-eligibility states; transaction-state continuity; multi-intermediary traceability; operational continuity; and preservation of institutional authority.
Summary
The anonymous public comment addresses intermediary participation in the FedNow® Service and related amendments to Regulation J. It presents a lifecycle-separated perspective on authorization, participation eligibility, compliance continuity, and transaction-state representation across intermediary-enabled payment pathways.
The filing addresses:
• authorization-state representation;
• participation-eligibility representation;
• compliance continuity and operational traceability;
• transaction-state consistency across intermediary pathways;
• audit alignment across institutional boundaries;
• interoperability with existing payment infrastructure; and
• cross-border transactions in which FedNow® supports the domestic settlement leg.
The comment explains that consistent transaction-state information may improve operational clarity and supervisory readability without modifying payment rails, participant connectivity, execution, settlement, transaction finality, or institutional authority.
Historical Context
This is the earliest publicly posted Federal Reserve comment that VeloxVFX LLC identifies within its regulatory-engagement chronology. Later Federal Reserve submissions—including OP-1878, R-1892, R-1893, R-1835, R-1885, R-1895, and OP-1880—expanded upon related concepts involving lifecycle separation, operational continuity, supervisory readability, evidence continuity, Payment Account governance, and preservation of institutional responsibility.
VELOXVFX LLC • Public Comments
FDIC—Federal Deposit Insurance Corporation
FDIC-Federal Deposit Insurance Corporation
Reciprocal Deposits: Implementing the 21st Century ROAD to Housing Act
September 1, 2026
FDIC — RIN 3064-AG32
Public Submission
Received: September 1, 2026
Posted: September 16, 2026
View Official Rulemaking Record FDIC.GOV
Subject
FDIC RIN 3064-AG32 — reciprocal deposits; regulatory qualification; placement and receipt; holding and reporting states; exception handling; correction and requalification; institutional record continuity; reviewable evidence; and preservation of legally authorized supervisory and institutional responsibility.
Summary
VeloxVFX LLC submitted an independent, architecture-oriented public comment concerning the FDIC’s implementation of reciprocal-deposit provisions under the 21st Century ROAD to Housing Act.
The submission addresses the distinction among qualification, placement, receipt, holding, reporting, exception, correction, and requalification states and explains that regulatory qualification does not itself establish that a deposit was placed, received, held, reported, or subsequently remained qualified.
The comment further addresses preservation of reviewable evidence and institutional continuity across changes in deposit status, operational handling, correction, and reporting without transferring regulatory judgment or supervisory authority.
VeloxVFX LLC does not determine reciprocal-deposit eligibility, regulatory classification, reporting treatment, supervisory status, or compliance. Those determinations remain with the institution and legally authorized authorities under applicable law.
VELOXVFX LLC • Public Comments
FDIC-Federal Deposit Insurance Corporation
Disclosure of Information Comments
June 30, 2026
FDIC — RIN 3064-AG30
Public Submission
Received: August 30, 2026
View Official Rulemaking Record FDIC.GOV
Subject
FDIC RIN 3064-AG30 — confidential-information disclosure; source and authority attribution; authorized purposes and recipients; confidentiality and privilege restrictions; risk-tiered safeguards; onward-sharing controls; correction, revocation, and closure; and institutional accountability.
Summary
VeloxVFX LLC submitted an independent, architecture-oriented public comment concerning the FDIC’s proposed modernization and clarification of its regulations governing confidential information and related records.
The comment proposes a technology-neutral, lifecycle-separated disclosure record preserving the information’s source and classification, the basis and purpose of disclosure, the responsible decision-maker, authorized recipients, applicable restrictions and safeguards, onward-sharing limitations, correction history, and revocation or closure states.
The submission emphasizes that information may move across authorized institutional boundaries while authority and responsibility remain identifiable. The proposed record would not determine whether disclosure is lawful, waive privilege, authorize a recipient, or replace FDIC or institutional judgment.
VELOXVFX LLC • Public Comments
FDIC-Federal Deposit Insurance Corporation
Bank Secrecy Act and Sanctions Compliance Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers
June 5, 2026
FDIC — RIN 3064-AG29
Public Submission
Received: August 30, 2026
View Official Rulemaking Record FDIC.GOV
Subject
FDIC RIN 3064-AG29 — Bank Secrecy Act, anti-money-laundering, and sanctions-compliance standards; supervisory consultation; examination procedures; meaningful human review; structured interoperability; supervisory readability; privilege preservation; operational continuity; and institutional-boundary protection.
Summary
VeloxVFX LLC submitted this public comment in response to the FDIC’s proposed implementation of Bank Secrecy Act and sanctions-compliance standards for FDIC-supervised permitted payment stablecoin issuers.
The submission presents an informational and architecture-oriented perspective concerning:
structured representation of compliance and supervisory states;
supervisory readability and examination support;
operational continuity and evidence preservation;
meaningful human review of material decisions and exceptions;
privilege and confidentiality preservation;
structured interoperability across regulated institutions and authorized agencies; and
clear separation of institutional responsibilities, legal authority, and operational functions.
The comment emphasizes that compliance, supervisory, examination, and enforcement functions should remain attributable to the legally authorized agency, institution, or responsible actor. Architecture may support evidence organization, continuity, review, and regulatory readability, but it should not replace legal interpretation, agency judgment, institutional accountability, or human authorization where required.
VELOXVFX LLC • Public Comments
FDIC-Federal Deposit Insurance Corporation
GENIUS Act Requirements and Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers And Insured Depository Institutions
FDIC — RIN 3064-AG19
Public Submission
This entry consolidates VeloxVFX LLC’s original public comment and two supplemental submissions concerning the FDIC’s proposed implementation of requirements under the GENIUS Act.
The filings are presented below according to their original submission dates. The May 6 supplemental submission was not initially displayed on the FDIC’s public-comment page. After VeloxVFX LLC submitted an inquiry, the FDIC added that filing after the June 9 submission had already been published. Consequently, the FDIC’s current labels—“Supplemental Comment” and “Supplemental Comment II”—do not reflect the chronological order of submission.
Original Public Comment
Transaction-State Representation, Continuity, and Lifecycle Separation
Received: April 27, 2026
Supplemental Submission 1
Structural Classification of Non-Executing State Representation and Yield- or Reward-Generating Functions
Submitted: May 6, 2026
FDIC display label: Supplemental Comment II
Supplemental Submission 2
Regulatory Relevance of Non-Executing State Representation to Interest, Yield, Rewards, Reserve-Asset Integrity, and Tokenized-Deposit Classification
Submitted: June 9, 2026
FDIC display label: Supplemental Comment
View Official Rulemaking Record FDIC.GOV
Subject
FDIC RIN 3064-AG19 — GENIUS Act implementation; permitted payment stablecoin issuers; reserve-asset integrity; interest, yield, and reward classification; tokenized-deposit treatment; non-executing state representation; supervisory readability; and institutional-boundary preservation.
Summary
Taken together, the original comment and two supplemental submissions distinguish regulated financial activity from non-executing technical frameworks that represent, preserve, communicate, or make reviewable transaction, custody, authorization, compliance, eligibility, continuity, audit, and lifecycle states.
The submissions recommend evaluating interest, yield, reward, affiliate, related-party, branded, and indirect arrangements according to their economic substance. A non-executing state-representation framework should not itself be treated as providing interest, yield, rewards, or another financial return when it does not confer holder-facing economic value or operate to evade applicable regulatory requirements.
The submissions further explain that non-executing state representation does not itself:
deploy, lend, pledge, invest, reuse, encumber, or rehypothecate reserve assets;
generate, calculate, allocate, accrue, fund, control, or distribute yield or rewards;
manage reserves or customer assets;
create redemption rights or establish pass-through deposit insurance;
intermediate deposits or determine tokenized-deposit treatment;
perform custody, settlement, payment processing, or money transmission; or
convert informational states into deposit-like or financial-return arrangements.
The consolidated record supports clearer classification, reserve-asset integrity, consumer protection, supervisory readability, evidence continuity, and separation between actual financial activity and informational, compliance-oriented, continuity, and audit-support infrastructure.
VELOXVFX LLC • Public Comments
OCC—Comptroller of the Currency
Office of the Comptroller of the Currency
Community Reinvestment Act Regulations — Joint Rulemaking
August 12, 2026
JOINT-AGENCY COUNTERPART
OCC — RIN: 1557-AF57
FDIC — RIN 3064-AG31
Public Submission
Posted | September 09, 2026
ID OCC-2026-0694-0018
View Official regulations.gov Record
Subject
OCC Docket OCC-2026-0694 — Community Reinvestment Act evaluation clarity; community-development eligibility; measurable outcomes; grant accountability; consumer access; public-benefit delivery; proportional reporting; institutional record continuity; and preservation of supervisory responsibility.
Summary
VeloxVFX LLC submitted a public comment in response to the joint OCC–FDIC Community Reinvestment Act rulemaking.
The filing responds to Questions 1–63 and addresses distinctions among qualifying activity, eligibility, institutional evaluation, delivered public benefit, measurable outcomes, correction, and supervisory determination.
The comment further addresses grant accountability, public-plan transparency, consumer access, assessment-area records, transition and correction states, and preservation of institutional responsibility and reviewable evidence.
The filing is informational and reflects the independent views of VeloxVFX LLC. The OCC, FDIC, and other legally authorized institutions retain responsibility for all regulatory interpretations, evaluations, and supervisory determinations.
VELOXVFX LLC • Public Comments
OCC — Controller of the Currency
Violations of Laws or Regulations
Sep 1, 2026
OCC — RIN 1557-AF56
OCC — Docket OCC-2026-0529
Public Submission
Posted | September 03, 2026
ID OCC-2026-0529-0002
View Official regulations.gov Record
Public Submission
Violations of Laws or Regulations: Lifecycle-Separated Supervisory Classification, Correction Records, Institutional Accountability, and Public-Interest Protection
Subject
OCC Docket OCC-2026-0529 — violations of laws or regulations; matters requiring attention; substantive and technical distinctions; correction and remediation records; supervisory readability; evidence continuity; institutional accountability; customer and public-interest protection; and preservation of legally authorized supervisory discretion.
Summary
VeloxVFX LLC submitted an independent, architecture-oriented public comment concerning the OCC’s proposed revisions addressing violations of laws or regulations, matters requiring attention, and violations for which the OCC does not take an enforcement action or issue a matter requiring attention.
The submission recommends that supervisory records preserve clear and reviewable distinctions among:
the applicable legal or regulatory requirement and the factual basis for the finding;
substantive violations and technical, clerical, documentation, timing, or reporting deficiencies;
materiality, duration, frequency, recurrence, and customer impact;
actual harm, potential harm, operational exposure, and control weaknesses;
correction, remediation, verification, escalation, closure, and reopening states;
later evidence affecting classification or materiality; and
the responsible institutional actors and supervisory authorities.
The comment explains that structured records may support supervisory readability, evidence continuity, correction traceability, and meaningful review without automatically determining the appropriate supervisory response. Correction history should be preserved rather than overwritten, including what changed, when it changed, who authorized the change, and how the new information affected the issue’s status.
Clear records may also help authorized examiners determine whether an issue affected customers, continued across reporting periods, recurred after correction, or required additional remediation. Closing an administrative or documentation task should not, by itself, represent that the underlying customer, compliance, governance, or safety-and-soundness concern has been resolved.
The proposed informational framework would not determine whether a violation occurred, classify conduct, issue or terminate a matter requiring attention, select a supervisory response, establish materiality, excuse noncompliance, or constrain the OCC’s statutory discretion. Those determinations remain with the OCC and other legally authorized decision-makers.
VELOXVFX LLC • Public Comments
OCC—Comptroller of the Currency
Guiding and Establishing National Innovation for U.S. Stable coins Act for the Issuance Of Stable coins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency
March 2, 2026
Posted : April 27, 2026
Entity: Anonymous 4
Public Submission
Public Comment: Separation Between Transaction-State Representation and Execution.
View Official OCC Public-Comment Record
View OCC-Hosted Anonymous 4 Filing PDF
OCC—Comptroller of the Currency
Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency
March 2, 2026
Posted : April 29, 2026
Entity: Anonymous 5
Public Submission
View Official OCC Public-Comment Record
View OCC-Hosted Anonymous 5 Filing PDF
OCC—Comptroller of the Currency
Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency
March 2, 2026
Received Date: May 17, 2026
Public Submission
View Official OCC Public-Comment Record
View OCC-Hosted Anonymous 5 Filing PDF
Summary
The May 17 supplemental OCC comment presented lifecycle-separated continuity representation and non-executing infrastructure concepts for OCC-supervised stablecoin environments, with emphasis on operational resilience, audit-oriented traceability, institutional interoperability, and supervisory readability. It expressly preserved institutional authority, AML/CFT and sanctions obligations, consumer protections, supervisory accountability, and externally governed implementation discretion.
VELOXVFX LLC • Public Comments
OCC—Comptroller of the Currency
Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism and Sanctions Compliance Risk Management
June 24, 2026
Posted: June 29, 2026
ID OCC-2026-0463-0001
Public Submission
Public Comment recommends lifecycle-separated state representation for reserve-state traceability, redemption-access continuity, confidential supervisory information, OCC-FinCEN consultation, sanctions-related reviewability, non-duplicative supervision, and institutional-boundary clarity.
View OCC-Hosted VeloxVFX LLC Filing
View Official OCC Public-Comment Record
regulations.gov/document/OCC-2026-0463-0001
VELOXVFX LLC • Public Comments
TREAS-U.S. Department of the Treasury
U.S. Department of the Treasury
GENIUS Act — Issuance, Offering, and Sale of Payment Stablecoins in the U.S.
August 17, 2026
Docket: TREAS-DO-2026-0496
Posted: September 9, 2026
VeloxVFX LLC Public Comment
Received Date: August 18, 2026
Public Record Status: Published
Subject
GENIUS Act Section 3 implementation; payment-stablecoin issuance, offering and sale; jurisdictional and institutional boundaries; lifecycle-separated state representation; compliance continuity; responsible-actor attribution; interoperability; and preservation of governmental and institutional authority.
Summary
VeloxVFX LLC submitted an independent, architecture-oriented public comment concerning Treasury’s proposed implementation of Section 3 of the GENIUS Act.
The submission addresses how payment-stablecoin activity may be represented through distinguishable lifecycle and institutional states while preserving the legal responsibilities of permitted payment stablecoin issuers, financial institutions, intermediaries, customers, and governmental authorities.
The comment distinguishes technical interoperability, information exchange, and state representation from the legal authority governing issuance, licensing, custody, settlement, compliance, and other regulated functions.
It further addresses continuity across independently governed institutions and jurisdictions, reviewable evidence, responsible-actor attribution, and preservation of legally operative determinations by the appropriate authorized institution or governmental authority.
Boundary Statement
VeloxVFX LLC does not issue or redeem payment stablecoins, provide custody, process payments, transmit money, determine licensing or eligibility, exercise supervisory or enforcement authority, or act on behalf of the U.S. Department of the Treasury or any other governmental agency.
Publication establishes inclusion of the submission in the public record only. It does not establish Treasury adoption, endorsement, approval, reliance, implementation, procurement, licensing, or validation.
View Official Treasury Public-Comment Record →
View Treasury-Hosted VeloxVFX Filing →
U.S. Department of the Treasury
GENIUS Act — Supplemental Public Comment on the Issuance, Offering, and Sale of Payment Stablecoins in the U.S.
August 24, 2026
Docket: TREAS-DO-2026-0496-0003
Posted: September 9, 2026
VeloxVFX LLC Supplemental Public Comment
Received Date: August 27, 2026
Public Record Status: Published
Subject
Supplemental GENIUS Act Section 3 implementation; jurisdictional continuity; transaction and relationship-state distinctions; cross-border and institutional handoffs; evidence continuity; responsible-actor attribution; and preservation of governmental and institutional authority.
Summary
VeloxVFX LLC submitted a supplemental public comment concerning Treasury’s proposed implementation of Section 3 of the GENIUS Act and expanding upon its August 18, 2026 submission.
The supplemental comment further develops the distinction between informational or technical state representation and legally operative determinations concerning issuance, offering, sale, licensing, jurisdiction, custody, settlement, compliance, and institutional responsibility.
It addresses changes in technical, transactional, geographic, and intermediary states; continuity across institutional and jurisdictional handoffs; preservation of prior and superseding states; reviewability of material changes; and attributable responsibility.
The supplemental filing complements the August 18 submission and does not replace it.
Boundary Statement
VeloxVFX LLC does not exercise Treasury authority, determine whether activity legally constitutes issuance, offering, or sale in the United States, determine licensing status, conduct regulated financial activity, or act on behalf of any governmental authority or regulated institution.
Publication establishes inclusion of the supplemental submission in the public record only. It does not establish Treasury adoption, endorsement, approval, reliance, implementation, procurement, licensing, or validation.
TREAS-U.S. Department of the Treasury
Based Principles for Determining Whether a State-level Regulatory Regime Is Substantially Similar to the Federal Regulatory Framework
This section contains an early public-facing, anonymous comment submitted to the U.S. Department of the Treasury concerning principles for determining substantial similarity between state and federal regulatory frameworks under the GENIUS Act.
Posted by the Department of the Treasury on Apr 3, 2026
Submitted by: Anonymous
Publication Date: April 24, 2026
Received Date: April 23, 2026
Historical Position:
Early public-facing regulatory submission; later named VeloxVFX LLC filings developed related institutional-boundary, continuity, and interoperability.
Title
GENIUS Act Broad-Based Principles for Determining Whether a State-level Regulatory Regime Is Substantially Similar to the Federal Regulatory Framework
Closed for Comments
Subject: Treasury GENIUS Act Regulatory-Regime Submission — Functional Consistency, Authorization and Participation Clarity, Compliance Continuity, Jurisdictional Interoperability, Regulatory-Fragmentation Reduction, and Preservation of Institutional Authority.
Summary
This early public-facing submission presents a general structural perspective on how the U.S. Department of the Treasury may evaluate whether a state-level regulatory regime is substantially similar to the applicable federal framework under the GENIUS Act.
The comment recommends emphasizing functional consistency over structural identity. It explains that state and federal frameworks may differ in form while still producing materially comparable outcomes through equivalent authorization standards, participation conditions, supervisory expectations, compliance requirements, and institutional safeguards.
The submission addresses:
clarity of authorization and participation conditions before operational processing;
continuity of compliance interpretation across state and federal jurisdictions;
traceability of regulatory and compliance determinations across systems;
reduction of fragmentation in eligibility, compliance, and supervisory treatment;
interoperability between independently governed jurisdictional frameworks; and
preservation of federal, state, institutional, supervisory, execution, and enforcement authority.
The comment further explains that substantial similarity should not require state systems to replicate federal structures. Instead, the analysis may focus on whether regulated entities remain subject to materially equivalent conditions and whether regulatory outcomes remain aligned despite procedural or institutional differences.
This submission was filed anonymously and formed part of the earliest public-facing record later associated with the broader VeloxVFX regulatory-engagement chronology. The Journal should preserve that historical status and should not retroactively identify VeloxVFX LLC as the named commenter on the Treasury docket.
The comment was provided for informational, structural, educational, and public-record purposes only, without requesting agency action, response, adoption, endorsement, procurement, implementation, or operational integration.
View Official TREAS Public-Comment Record
https://www.regulations.gov/document/TREAS-DO-2026-0232-0001/comment
View TREAS-Hosted Anonymous Filing PDF
U.S. Securities and Exchange Commission and Commodity Futures Trading Commission
U.S. Securities and Exchange Commission and Commodity Futures Trading Commission
Joint Request for Comment on Further Implementation of Portfolio Margining and Cross-Margining of Securities and Derivatives
Posted: June 30, 2026
Comment Posted: July 18, 2026
Received Date: July 18, 2026
Summary
VeloxVFX LLC submitted an independent, architecture-oriented public comment responding to the joint SEC–CFTC request concerning further implementation and potential harmonization of portfolio margining and cross-margining across securities and derivatives markets.
The submission addresses how separately governed market participants and financial-market infrastructures may preserve readable and consistent representations of:
collateral state;
margin state;
valuation-reference state;
transfer and settlement state;
timing state;
threshold state;
legal-reference state;
exception and review state;
account and customer-protection state; and
operational-continuity state.
The comment presents lifecycle-separated continuity representation as a means of supporting operational resilience, supervisory readability, audit-oriented traceability, and structured interoperability without transferring or replacing the independently governed responsibilities of broker-dealers, futures commission merchants, clearing agencies, derivatives clearing organizations, exchanges, custodians, clearing members, or regulatory agencies.
The architecture-oriented position does not calculate or impose margin requirements, value positions, net exposures, move collateral, execute transfers, clear or settle transactions, determine legal eligibility, alter segregation requirements, exercise liquidation authority, or perform supervisory or enforcement functions.
The submission was provided for informational, architecture-oriented, educational, structural-classification, regulatory-relevance, and public-record purposes only. It did not request or imply agency adoption, endorsement, procurement, approval, implementation, testing, operational integration, institutional reliance, supervisory authority, enforcement authority, or modification of independently governed institutional responsibilities.
View Official SEC Public-Comment Record
https://www.sec.gov/rules-regulations/public-comments/s7-2026-23
View SEC-Hosted VeloxVFX LLC Filing PDF
https://www.sec.gov/comments/S7-2026-23/s7202623-966579-2998266.pdf
U.S. Securities and Exchange Commission and Commodity Futures Trading Commission
Further Definition of ``Swap'' and ``Security-Based Swap'' and on Alternative Compliance
Posted: Jun 24, 2026
Comment Posted: July 31, 2026
Received Date: July 30, 2026
Entity: VeloxVFX LLC
Summary
VeloxVFX LLC submitted an independent, architecture-oriented public comment addressing the classification of swaps, security-based swaps, mixed swaps, statutory exclusions, and alternative compliance. The submission recommends product-level records that preserve legal, economic, jurisdictional, and lifecycle evidence while supporting coordinated SEC-CFTC procedures. It emphasizes that technical evidence may improve classification clarity and reviewability but does not make legally operative determinations, merge agency authority, or replace Commission supervision, interpretation, or enforcement.
View Official CFTC Public-Comment Record
https://www.regulations.gov/document/CFTC-2026-1355-0001/comment
View CFTC-Hosted VeloxVFX LLC Filing PDF
U.S. Securities and Exchange Commission and Commodity Futures Trading Commission
Swap and Security-Based Swap Data Reporting
Posted: Jun 24, 2026
Comment Posted: July 31, 2026
Received Date: July 30, 2026
Entity: VeloxVFX LLC
Summary
VeloxVFX LLC submitted an independent, architecture-oriented public comment addressing harmonization of swap and security-based swap data reporting. The submission recommends a common reporting-data core with agency-specific extensions, preserved transaction lineage, event-specific reporting responsibility, versioned validation logic, governed identifiers and reference data, correction history, and coordinated implementation. It emphasizes that reporting harmonization should improve data quality, regulatory usability, and evidence continuity without merging SEC and CFTC authority or allowing machine-readable logic, blockchain records, or technical identifiers to replace required reporting, legal interpretation, or agency judgment.
View Official CFTC Public-Comment Record
https://www.regulations.gov/document/CFTC-2026-1354-0001/comment
View CFTC-Hosted VeloxVFX LLC Filing PDF
CFTC-Commodity Futures Trading Commission
CFTC-Commodity Futures Trading Commission
Innovation Advisory Committee — Inaugural Meeting Written Statement
August 20, 2026
Posted: August 20, 2026
Received Date: August 21, 2026
Comment Posted: August 24, 2026
Entity: VeloxVFX LLC
Summary
VeloxVFX LLC submitted an independent, architecture-oriented written statement in connection with the Commodity Futures Trading Commission’s inaugural Innovation Advisory Committee meeting addressing crypto-market structure, artificial intelligence and autonomous systems, prediction markets, and related financial-market innovation.
The submission addresses institutional interoperability through machine-readable state representation while preserving legally distinct authority, responsibility, custody, and execution-related boundaries across participating institutions.
The statement emphasizes that information may become interoperable across traditional and digital financial environments without consolidating legal or operational authority. It further addresses lifecycle-state attribution, institutional handoffs, evidence continuity, reviewability, and preservation of responsibility among independently governed market participants.
The submission is informational and architecture-oriented. It does not request or imply Commission adoption, endorsement, approval, procurement, implementation, operational integration, supervisory reliance, licensing, certification, or transfer of CFTC or market-participant authority.
View Official CFTC Innovation Advisory Committee Record
https://www.regulations.gov/document/CFTC-2026-1717-0001/comment
View VeloxVFX LLC Filing PDF
CFTC-Commodity Futures Trading Commission
Standard Futures Contracts to 24/7 Trading and on Perpetual Contracts Referencing Physically Delivered or Storable Energy Commodities
Jul 28, 2026
Posted: Jul 28, 2026
Comment Posted: August 26, 2026
Received Date: August 22, 2026
Entity: VeloxVFX LLC
Docket: CFTC-2026-1388
RIN: 3038-AF75
Comment ID: CFTC-2026-1388-0109\
Summary
VeloxVFX LLC submitted Supplemental Public Comment II in connection with the Commodity Futures Trading Commission’s request for comment concerning extension of standard futures contracts to 24/7 trading and perpetual contracts referencing physically delivered or storable energy commodities.
The filing supplements VeloxVFX LLC’s July 19, 2026 initial public comment and July 28, 2026 supplemental comment and addresses institutional considerations associated with continuous-market infrastructure, including collateral and margin readiness, Treasury-security and other collateral-state distinctions, clearing and payment continuity, benchmark integrity, custody and release boundaries, operational resilience, and preservation of institutional responsibility.
The submission emphasizes that continuous technical availability should remain distinguishable from continuous institutional readiness. It presents separately attributable market, collateral, custody, payment, clearing, exception, recovery, and responsibility states as informational architecture concepts that may support reviewability across continuously available markets without transferring execution, clearing, settlement, custodial, margin, supervisory, or regulatory authority.
References to USDCC, VeloxFX, and FiVaultAI are used solely as functional architecture-mapping labels. The filing does not request or imply CFTC adoption, endorsement, approval, procurement, implementation, reliance, operational integration, licensing, certification, or transfer of Commission or market-participant authority.
View Official CFTC Public-Comment Record
https://www.regulations.gov/comment/CFTC-2026-1388-0109
View VeloxVFX LLC Filing PDF
https://www.regulations.gov/comment/CFTC-2026-1388-0109
CFTC-Commodity Futures Trading Commission
Standard Futures Contracts to 24/7 Trading and on Perpetual Contracts Referencing Physically Delivered or Storable Energy Commodities; Extension of Comment Period
Posted: July 28, 2026
Comment Posted: July 29, 2026
Received Date: July 28, 2026
Entity: VeloxVFX LLC
Summary
July 28, 2026 Supplemental CFTC Filing: The supplemental comment advanced the principle that continuous technical availability is not continuous market readiness and addressed off-hours liquidity, benchmark transmission, cross-contract surveillance, payment continuity, negative-price conditions, perpetual funding and wind-down, customer protection, and staged implementation. This aligns closely with the CFTC’s subsequent decision to extend the comment period, add questions after industry discussions, and maintain heightened review of proposed 24/7 crude-oil trading.
View Official CFTC Public-Comment Record
https://www.regulations.gov/document/CFTC-2026-1388-0061/comment
View VeloxVFX LLC Filing PDF
CFTC-Commodity Futures Trading Commission
Extension of Standard Futures Contracts to 24/7 Trading and on Perpetual Contracts Referencing Physically Delivered or Storable Energy Commodities
Jun 25, 2026
Posted: Jun 25, 2026
Comment Posted: July 22, 2026
Received Date: July 19, 2026
Entity: VeloxVFX LLC
Summary
July 19, 2026 Initial CFTC Filing: VeloxVFX LLC recommended that 24/7 energy-futures and perpetual-contract markets be evaluated through continuous evidence, surveillance, operational readiness, margin capability, human review, and safeguards for commercial users and the public. The filing strongly aligns with the CFTC’s current direction favoring responsible innovation while preserving asset-specific Core Principles, manipulation protections, and market stability.
View Official CFTC Public-Comment Record
https://www.regulations.gov/document/CFTC-2026-1388-0001/comment?filter=veloxvfx%20llc
View VeloxVFX LLC Filing PDF
SEC-U.S. Securities and Exchange Commission
SEC-U.S. Securities and Exchange Commission
Roundtable on Preparations for 24-Hour Trading
File No. 4-913
Agency Announcement Date: July 23, 2026
Public Record Date: August 12, 2026
Received Date: August 12, 2026
Entity: VeloxVFX LLC
Title
Preparations for 24-Hour Trading: Lifecycle-Separated Operational Readiness, Resiliency, Evidence Continuity, Investor Protection, and Institutional-Boundary Preservation
Subject
SEC File No. 4-913 — Preparations for 24-hour trading; lifecycle-separated operational readiness; session and time-state representation; operational resiliency; evidence continuity; investor protection; cross-institution coordination; recovery and reconciliation; and institutional-boundary preservation.
Summary
VeloxVFX LLC submitted an independent, architecture-oriented public comment in connection with the Securities and Exchange Commission’s Roundtable on Preparations for 24-Hour Trading.
The submission addresses how extended-hours and continuously available securities markets may preserve clear and reviewable representations of:
trading-session and market-state conditions;
business-date, trading-date, clearing-date, and settlement-date relationships;
system availability and dependency states;
degraded service and exception conditions;
recovery, reconciliation, and continuity states;
human-review and escalation requirements;
cross-institution testing and operational coordination;
evidence continuity and audit-oriented traceability; and
investor-protection and institutional-responsibility boundaries.
The comment emphasizes that continuous technical availability should remain distinguishable from continuous operational readiness. A continuously available trading environment may require reliable visibility into liquidity conditions, market dependencies, clearing and settlement availability, supervisory evidence, exception handling, recovery procedures, and responsible human escalation throughout the transaction lifecycle.
The submission presents lifecycle-separated state representation as an informational architecture concept that may support operational resilience, supervisory readability, investor protection, cross-institution coordination, and evidence continuity without transferring or replacing the independently governed responsibilities of exchanges, alternative trading systems, broker-dealers, clearing agencies, custodians, market-data providers, technology providers, regulators, or other authorized market participants.
The described framework does not operate a securities market, execute or route orders, provide investment advice, determine best execution, establish trading eligibility, calculate margin, perform surveillance, clear or settle transactions, custody assets, exercise supervisory authority, or make regulatory determinations.
Public-Record and Institutional Boundary
This submission is provided solely for informational, educational, architecture-oriented, and public-record purposes.
Its publication by the Securities and Exchange Commission does not indicate or imply SEC adoption, endorsement, approval, procurement, implementation, operational integration, supervisory reliance, licensing, certification, or any official relationship with VeloxVFX LLC.
All legally operative interpretations, market-structure determinations, supervisory decisions, examinations, enforcement actions, operational responsibilities, and exercises of statutory authority remain exclusively with the Securities and Exchange Commission and other legally authorized institutions under applicable law.
View Official SEC Public-Comment Record
https://www.sec.gov/rules-regulations/public-comments/4-913
View SEC-Hosted VeloxVFX LLC Filing PDF
NCUA—National Credit Union Administration
NCUA—National Credit Union Administration
Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the NCUA
Posted: May 18, 2026
Received Date: June 30, 2026
Entity: VeloxVFX LLC
Comments Lifecycle-Separated Credit-Union Relationship Classification, Supervisory Readability, Audit-State Traceability, and Institutional-Boundary Preservation
Summary
VeloxVFX LLC submitted an independent, architecture-oriented public comment addressing the NCUA’s proposed implementation of the GENIUS Act for payment-stablecoin issuers operating within the agency’s jurisdiction.
The comment recommends maintaining clear distinctions among:
credit-union membership relationships;
credit union service organization relationships;
permitted payment stablecoin issuer customer relationships;
authorized service-provider relationships;
independent intermediary relationships;
redemption-request states;
reliance states;
exception-review states;
audit-state records; and
continuity-state references.
The submission explains that possession of a payment stablecoin, association with a wallet address, interaction with a smart contract, or participation in secondary-market activity should not, standing alone, establish:
credit-union membership;
CUSO responsibility;
a direct issuer-customer relationship;
a service-provider relationship;
institutional reliance; or
another legally regulated institutional relationship.
The comment presents lifecycle-separated relationship-state classification as a method of supporting supervisory readability, audit-oriented traceability, proportional implementation, operational continuity, exception awareness, and preservation of institutional boundaries.
The described framework remains informational and nonexecuting. It does not perform AML/CFT procedures, sanctions screening, identity verification, custody, payment processing, settlement, money transmission, institutional authorization, or regulatory decision-making.
The submission was provided for informational, architecture-oriented, educational, structural-classification, regulatory-relevance, and public-record purposes only. It did not request or imply agency adoption, endorsement, procurement, approval, implementation, operational integration, institutional reliance, modification of agency authority, or modification of independently governed credit-union, CUSO, issuer, intermediary, or service-provider responsibilities.
View Official NCUA Public-Comment Record
https://www.regulations.gov/document/NCUA-2026-1024-0001/comment?filter=VELOXVFX
View VeloxVFX LLC Filing PDF
Unified Interagency Public Comment
Unified Interagency Public Comment
Permitted Payment Stablecoin Issuer Customer Identification Program
Posted: June 22, 2026
Received Date: June 25, 2026
Entity: VeloxVFX LLC
Agency Financial Crimes Enforcement Network
Submitted in response to the joint proposed rule issued by:
Financial Crimes Enforcement Network
Office of the Comptroller of the Currency
Board of Governors of the Federal Reserve System
Federal Deposit Insurance Corporation
National Credit Union Administration
Public Submission
Document Subtype Comment(s): Lifecycle-Separated Customer-Identification-State Representation(CIP)
Summary
This public comment responds to federal Customer Identification Program (CIP) and related identity-verification rulemakings by presenting a lifecycle-separated approach to customer, transaction, verification, review, and institutional state representation. The submission focuses on improving supervisory readability, interoperability, evidence continuity, and institutional-boundary preservation while maintaining that all legally operative identification, compliance, supervisory, and enforcement authority remains exclusively with the appropriate governmental agencies and regulated institutions.
View Official FinCEN- Unified Public-Comment Record
https://www.regulations.gov/document/FINCEN-2026-0101-0001/comment
View FinCEN- Unified-Hosted VeloxVFX LLC Filing PDF
FinCEN—Financial Crimes Enforcement Network
FinCEN—Financial Crimes Enforcement Network
Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements
Posted: April 10, 2026
Received Date: June 7, 2026
Public Submission
Comment(s): Supplemental Non-Executing Transaction-State Representation, Secondary-Market Risk Visibility, Lawful-Order Traceability, AML/CFT Program Effectiveness, and Sanctions-Compliance Continuity
Consolidated Summary
Together, the initial and supplemental submissions present an informational and architecture-oriented perspective on how non-executing transaction-state representation may support AML/CFT program effectiveness, sanctions-compliance continuity, supervisory readability, secondary-market risk visibility, lawful-order traceability, operational resilience, and evidence preservation.
The submissions discuss how transaction, authorization, review, exception, compliance-reference, lawful-order, sanctions-awareness, eligibility, and continuity states may be represented and preserved throughout a transaction lifecycle. This representation is intended to improve continuity and reviewability without transferring, replacing, originating, or exercising the legal, supervisory, compliance, sanctions, enforcement, or operational authority of regulated financial institutions or governmental agencies.
The supplemental submission further develops the April record by emphasizing secondary-market visibility, lawful-order traceability, sanctions-awareness continuity, and the preservation of authority boundaries across multi-institution transaction environments.
The consolidated record distinguishes informational and continuity-oriented infrastructure from systems or actors that:
execute, clear, or settle transactions;
block, freeze, reject, or release assets;
determine sanctions status or legal eligibility;
conduct regulated AML/CFT operations;
originate legal, supervisory, or enforcement decisions;
custody or control customer assets;
process payments or transmit money; or
exercise governmental or regulated institutional authority.
The submissions support clearer state representation, supervisory readability, evidence continuity, operational resilience, and institutional accountability while preserving the independent responsibilities and legal authority of FinCEN, OFAC, regulated financial institutions, and other authorized bodies.
View Official FinCEN Public-Comment Record
https://www.regulations.gov/document/FINCEN-2026-0101-0001/comment
View FinCEN-Hosted VeloxVFX LLC Supplemental Filing PDF
FinCEN—Financial Crimes Enforcement Network
Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements
Posted: April 10, 2026
Received Date: April 26, 2026
Entity: Anonymous
Public Submission
Comment(s): Structured, lifecycle-based perspective on transaction-state representation within payment processing and transaction-handling systems in the context of AML/CFT program effectiveness, sanctions compliance, and compliance continuity.
View Official FinCEN Public-Comment Record
https://www.regulations.gov/document/FINCEN-2026-0100-0001/comment?filter=Anonymous
View FinCEN-Hosted Anonymous Filing PDF
Department of the Treasury / Internal Revenue Service
Department of the Treasury / Internal Revenue Service
Guidance on Eligible Investments for Trump Accounts
Posted: Aug 21, 2026
Docket: IRS-2026-1090
RIN: 1545-BS14
Regulation ID: CC-00349938-26
Federal Register: FR Doc. 2026-17123
Received Date: August 23, 2026
Entity: VeloxVFX LLC
Summary
VeloxVFX LLC submitted an independent, architecture-oriented public comment concerning the proposed guidance governing eligible investments for Trump Accounts.
The submission addresses long-duration account administration, investment-eligibility state, trustee responsibility, periodic review, actual-knowledge events, correction periods, disclosure, institutional handoffs, and beneficiary-facing information clarity.
The comment emphasizes lifecycle-separated information representation while preserving the respective authority of Treasury, the IRS, trustees, custodians, responsible parties, beneficiaries, and other legally authorized institutions.
The submission further distinguishes Trump Account investment eligibility from separate Treasury-security, collateral, stablecoin, and broader market-structure contexts.
The submission is informational and technology-neutral and does not request or imply Treasury or IRS adoption, endorsement, approval, procurement, implementation, operational integration, or transfer of governmental, fiduciary, custodial, investment, or execution authority.
View Official Public Record
https://www.regulations.gov/document/IRS-2026-1090-0001/comment
View IRS-Hosted VeloxVFX LLC Filing PDF
FASB — Financial Accounting Standards Board
FASB — Financial Accounting Standards Board
Statement of Cash Flows (Topic 230): Cash Equivalents—Disclosure Enhancement and Classification of Certain Digital Assets
File Reference No.: 2026-ED400
Exposure Draft Issued: August 18, 2026
VeloxVFX Comment Submitted: August 28, 2026
FASB Public-Record Status: Published
Publication Confirmed: September 4, 2026
Comment Letter: No. 1
Entity: VeloxVFX LLC
Commenter: Eyad G. Haddadin
Public Submission
Subject
FASB File Reference No. 2026-ED400 — Statement of Cash Flows (Topic 230); classification of certain digital assets as cash equivalents; significant classes of cash equivalents; reserve composition; direct redemption rights; legal and regulatory compliance; economic characteristics; accounting transparency; disclosure; and treatment of digital-asset structures.
Summary
VeloxVFX LLC submitted an independent public comment in response to the Financial Accounting Standards Board’s proposed Accounting Standards Update concerning cash-equivalent disclosure and the classification of certain digital assets.
The submission addresses the importance of distinguishing an asset’s technical form from its economic characteristics, contractual redemption rights, reserve structure, legal status, and resulting accounting treatment.
The comment emphasizes that digital representation alone should not determine whether an asset qualifies as a cash equivalent. Classification should remain connected to the economic and contractual characteristics relevant to the applicable accounting standard, including liquidity, redemption rights, reserve composition, legal and regulatory conditions, and the nature of the holder’s claim.
The submission further addresses the treatment of wrapped, bridged, receipt, derivative, or otherwise transformed digital-asset structures, where additional contractual, intermediary, counterparty, technological, or redemption relationships may distinguish the resulting instrument from the underlying asset.
Financial-Reporting and Market Relevance
The submission addresses a financial-reporting boundary that complements regulatory treatment of digital assets.
A digital asset may be technically transferable or economically associated with cash without necessarily possessing the same contractual rights, reserve characteristics, redemption structure, legal status, or accounting classification as cash or a cash equivalent.
Preserving those distinctions can support clearer financial reporting, auditability, liquidity assessment, investor understanding, institutional risk management, and comparability across reporting entities.
The governing principle is:
Technical representation does not itself determine economic substance, legal status, or accounting classification.
Public-Record and Standard-Setting Boundary
This submission is provided solely for informational, accounting-policy, architecture-oriented, educational, and public-record purposes.
Publication of the VeloxVFX LLC comment by FASB confirms its inclusion in the public comment record. It does not indicate or imply FASB adoption, endorsement, agreement, approval, reliance, implementation, incorporation, validation, or acceptance of any VeloxVFX LLC recommendation, terminology, framework, or architecture.
The designation “Comment Letter No. 1” reflects FASB’s public-record presentation only. It does not establish filing priority, comparative importance, FASB preference, recognition, endorsement, or substantive acceptance.
FASB retains exclusive responsibility for its standard-setting process and authoritative accounting standards. Reporting entities, auditors, regulators, and other authorized parties retain their respective responsibilities under applicable accounting standards, securities laws, regulations, professional standards, and other applicable requirements.
View Official FASB Project Record
https://fasb.org/search?query=2026-ed400
View FASB-Hosted VeloxVFX LLC Comment Letter