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Use of Payment Stablecoins as Margin and Collateral Under the GENIUS Act

Introduction The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” or the “Act”) establishes a legal framework for defining, issuing, custodying and managing a specific kind of...more

Global Moves, Digital Shifts, July 2025 - Federal Banking Regulators on Crypto-Asset Safekeeping

Just days prior to the passage of the GENIUS Act on stablecoins by Congress, on July 14th, the Federal Reserve, Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (collectively, the...more

Operation and Structure of the GENIUS Act of 2025 on Payment Stablecoins

The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act” and the “Act”) establishes a regulatory infrastructure for defining, managing, custodying and issuing a specific kind of...more

Certainty and Uncertainty, May 2025 - Emerging Market Trends in Derivatives Industry

In the post-pandemic world, several trends are developing that will fundamentally change the way financial market participants manage commercial risk or trade traditional and rapidly evolving novel assets, while new classes...more

New Regulatory Priorities Spring Into Focus, April 2025 - Stablecoin Bills Moving to the Floor of the Senate and the House

As of Wednesday, stablecoin bills in the House and the Senate have been voted out of committee and moved onto the floor of each house for a full vote....more

New and Improved Stablecoin Legislation

We have reported on stablecoin regulation and legislation several times over the last few years, including on the most recent stablecoin legislation that appeared to have traction on a bi-partisan basis, the Lummis-Gillibrand...more

Crypto Capital of the Planet, but Without CBDCs

On January 23, President Trump issued an Executive Order and accompanying Fact Sheet intending to promote “United States leadership in digital assets and financial technology while protecting economic liberty.” Entitled...more

CFPB Warns of Dangers Related to Nonbanks Managing Payments and Issuing Stablecoins Outside of the Banking System

On October 6, 2023, Rohit Chopra, the Director of the Consumer Financial Protection Bureau (“CFPB”), gave a speech at the Brookings Institute’s “Payments in a Digital Century” event.  In his prepared remarks, Chopra frankly...more

NIST Stablecoin Report Highlights Security and Stability Concerns

The National Institute of Standards and Technology (“NIST”), a non-regulatory governmental agency that focuses upon the technological aspects of a wide variety of products and services, mostly non-financial in nature,...more

Federal Reserve Says Permission Required for State Banks to Be Involved in Stablecoin Issuance

The Federal Reserve issued a Supervision and Regulation letter earlier this week to all state member banks (“SMBs”) regarding their involvement in activities involving stablecoins, taking an even more reticent position than...more

FDIC Acting Chair Talks Prudential Regulation of Crypto-Assets

Last week, Martin Gruenberg, Acting Chair of the Federal Deposit Insurance Corporation (“FDIC”), gave remarks at the Brookings Institution on the Prudential Regulation of Crypto-Assets....more

U.S. Senators Propose First Comprehensive Regulation for Digital Assets

Earlier this week, U.S. Sens. Kirsten Gillibrand (D-N.Y.) and Cynthia Lummis (R-Wyo.) introduced the first comprehensive legislation to establish a regulatory framework for digital assets to promote innovation, delineate...more

Acting Comptroller Hsu Brings Crypto-Skepticism to Blockchain Summit

This week, Acting Comptroller of the Currency Michael Hsu gave remarks to the DC Blockchain Summit titled “Crypto: A Call to Reset and Recalibrate.” By speaking at the Blockchain Summit, Mr. Hsu may have gone into the...more

Yellen to Senate Banking Committee: Stablecoins Should Be Regulated

Earlier last week, Department of the Treasury Secretary Janet Yellen provided testimony and responded to questions from the Senate Banking Committee regarding volatility in cryptocurrencies that are designated to be...more

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