Paradigm has submitted a letter to the U.S. Treasury Department expressing concerns over the state-level regulatory pathway proposed under the GENIUS Act. While supporting the core framework, Paradigm highlights four critical issues that could undermine the effectiveness of the proposal. The letter criticizes the reliance on unfinished OCC regulations, which could hinder market access by requiring states and issuers to plan around uncertain benchmarks. Paradigm urges the Treasury not to finalize these rules prematurely. Additionally, Paradigm points out the lack of a decision-making timeframe and standards for veto interpretation in the proposal, which requires unanimous agreement from key financial authorities for certifying state-level systems. The firm suggests a 180-day decision period and a process for explaining vetoes. Concerns are also raised about the 12-month operating expense reserve requirement, which could disadvantage early issuers. Paradigm recommends allowing states to adjust reserves based on issuer size and risk. Lastly, the proposal's failure to address hostile actions by individual states is noted as a significant loophole that needs to be addressed.