Conference of State Bank Supervisors
In separate letters to the U.S. Treasury Department and the federal banking agencies, CSBS outlined important policy considerations to foster a national regulatory framework for stablecoins and tokenized deposits that protects consumers, promotes financial stability, and provides a level playing field for traditional financial institutions and new payment stablecoin issuers.
“Stablecoin and tokenized deposit efforts should proceed in tandem,” said CSBS President and CEO Brandon Milhorn. “All financial institutions that choose to innovate – from community banks to stablecoin issuers – should have the benefit of regulatory clarity so they can bring responsible blockchain-based financial products to market.”
CSBS’s letter to Treasury provides a blueprint for achieving the GENIUS Act’s vision of a robust state-federal regulatory framework that facilitates a dynamic and resilient stablecoin market in the United States. Importantly, the CSBS comments:
- Reinforce that the GENIUS Act’s “substantial similarity” standard creates a federal floor, not a requirement for nationwide uniformity;
- Encourage Treasury to maintain vital flexibility that allows issuers to choose between federal and state frameworks based on their organizational structures and business strategy; and,
- Argue for strict compliance with GENIUS Act limitations on financial activities by payment stablecoin issuers, along with robust capital and resolution planning requirements and federal rules that prevent evasion of the “interest” and “yield” prohibitions in the GENIUS Act.