#stablecoins

29 09, 2025

Karen Petrou: Why Stablecoins Must Also Reliably Settle and Clear 

2025-10-21T12:46:27-04:00September 29th, 2025|The Vault|

As we noted last week, a new study finds that stablecoins and other crypto payments use declined from 2022 to 2024 by about a third, now including less than two percent of U.S. households.  Further, these are disproportionately unbanked, with the only bit of growth in payment-stablecoin use coming from households with poor or very poor credit scores. Payee choice was the most important driver of decisions to use a payment stablecoin.  These jarring facts brings the trillions-of-trillions of dollars stablecoin dreamers back to earth with a hard thump.  They might still prevail, but only if banks don’t quickly counter with potent products and nonbanks also get the rules they want and the payees they need to redefine their problematic stablecoin value proposition.

One critical battle is already being waged.  Banks are fighting hard to prevent indirect payment of incentives that advantage stablecoin holders and thus undermine transaction-account alternatives.  This question is among the most important on which Treasury now seeks comment before it quickly starts writing rules.  The Senate Banking Committee might also revise the GENIUS Act at cost of bankers.

Despite the plethora of questions in Treasury’s recent request, another important issue is omitted: who may own a nonbank stablecoin issuer.  The Act as is contains a prohibition on ownership by publicly-traded nonfinancial companies, but Treasury can waive this ban if it and other regulators reach several findings that won’t be too hard to find if Treasury wants them unearthed. Pending changes in law and rule could also …

28 07, 2025

Karen Petrou: The High Cost to Competitiveness of the Bankers’ Quest for Certainty

2025-07-28T09:27:41-04:00July 28th, 2025|The Vault|

FedFin reports since at least 2011 have identified the comparative advantage nonbanks enjoy thanks to lots of costly bank-only standards.  However, we missed one big nonbank advantage sure to prove even more decisive in the stablecoin wars:  bankers crave regulatory certainty even as their competitors aggressively exploit the battlefield advantage that uncertainty gives to those who dare.

Bankers aren’t dare-devils because they’re not supposed to be.  Indeed, anyone who takes someone else’s money should be very, very careful.  Decades of accepting deposits under strict rules without meaningful competition meant that most bankers rightly asked a lot of questions before doing anything even a little bit novel.  To be sure, high-flying bankers abused taxpayer benefits thanks to negligent or even captive supervisors and rules weren’t always right.  Still, rules and the supervisors who enforced them generally kept bankers in their lane since there wasn’t any faster traffic.

This comfy balance between caution and competitiveness was fiercely challenged for the first time when money-market funds dawned in the late 1970s, luring bank deposits at a time when anachronistic rules barred banks from offering competitive interest rates.  High-flying bankers then sought to evade these constraints by making high-risk loans, thus bringing about the 1980s S&L crisis and the banking debacle that followed in the early 1990s.  Both of these were systemic in terms of taxpayer cost, but neither had macroeconomic or financial-stability impact.

Newer, better rules succeeded these crises, but they were outflanked as “nonbank banks” became the first commercial firms to exploit …

21 07, 2025

Karen Petrou: How New-Age ILCs Will Bust the Old Banking Paradigm

2025-07-22T12:54:27-04:00July 21st, 2025|The Vault|

As our forthcoming in-depth analysis will make clear, the FDIC’s request for information (RFI) on industrial loan company charters is a critical document to which one must respond in order to have any say in the future of banking as it may soon be set. This is easy to miss — RFIs are usually little more than a duck and cover. See for example the recent inter-agency RFI on payment fraud, from which one can deduce little but that the agencies think fraud is bad — questions asked, decisions deferred, discretion preserved. That is definitely not what the FDIC is about when it comes to ILCs – it is asking tough questions it will begin to answer even before RFI comments are submitted later this year. Who gets an ILC charter will determine winners and losers for decades to come, or so history teaches us.

Due to decisions deferred, the ILC charter has been an unresolved question since the 1980s. Congress then enacted the “Competitive Banking Act” which was anything but since all it did was grandfather the banking/commerce mixes achieved through ILCs through 1987 without quashing all those that came thereafter. As the FDIC notes, ILC and similarly chartered assets grew from $4 billion in 1987 to $213 billion by 2006, when more than a few of the most aggressive ILCs were in high-flying nonbanks that were then bailed out during the 2008 crisis.

One might have thought Congress, or the FDIC would then decide what to do with …

7 07, 2025

Karen Petrou: Stablecoin Banks and the Increasingly-Uncertain Future of Banking

2025-07-07T09:18:34-04:00July 7th, 2025|The Vault|

The CEO of a high-flying conglomerate named Textron once quipped that his investment bank’s c-suite had a long wall of his deal-done plaques and another facing wall just as replete with his deal-undone announcements.  The investment bank made money on the way up and down, as did he.  The big losers:  investors.  Is this a lesson for our times as stablecoin issuers line up for bank charters? Banks hope so, but I fear not.

The difference between Textron then and all the nonbanks gunning now for bank charters is that, in the way-back, Textron competed on the proverbial level playing field.  The reason most of its acquisitions went bust is because the economies of scale and scope Textron touted were mostly chimeras since technology and data then did not reward consolidation.  Now they do.

Even more importantly, the firms Textron bought were also under the same rules – such as they were – as their competitors.  Now, of course, this isn’t anywhere close to the case for bank competitors such as auto manufacturers, tech-platform companies, payment entities, and nonbank stablecoin issuers.

We have written before about how regulatory and merger-policy obstacles make it hard for all but the biggest banks to innovate as well as of the inequities of the pending legislation’s stablecoin regime.  We’re not the only ones who know this.  Nonbank issuers are already looking for additional avenues of regulatory arbitrage and they don’t have to look far.

Last week’s news brought announcements of national-bank applications from Circle

11 08, 2023

FedFin on : Stablecoin/Tokenization Activities

2023-08-11T16:25:47-04:00August 11th, 2023|The Vault|

In conjunction with issuing a new supervisory policy for “novel” activities, the FRB has instituted a new process requiring non-objection letters before state member banks proceed with stablecoin or dollar-tokenization activities.  Although the new non-objection process makes it clear that Fed approval will require clear adherence to a raft of policy and legal obligations, the non-objection process clears the way for state member banks to offer products with a growing role in retail and wholesale payment, settlement, and clearing activities.

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.…

14 02, 2023

FedFin on: Crypto Set For Senate AML, Reserve Rewrite

2023-02-15T16:13:52-05:00February 14th, 2023|The Vault|

Although Chairman Brown (D-OH) remained non-committal on the need for crypto legislation, he emphatically called for reform to protect consumers and investors.  Sen. Warren (D-MA) plans to reintroduce bipartisan legislation extending AML requirements to crypto firms, while Sen. Tillis (R-NC) announced that he is working on a bill addressing proof of reserves and asset segregation.  Sen. Lummis (R-WY) was not present, but also plans to reintroduce her sweeping crypto bill (see FSM Report CRYPTO28) in this Congress following revisions that reflect…

The full report is available to retainer clients. To find out how you can sign up for the service, click here and here.…

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