The Regulatory Map Banks Have Been Waiting For
Banks have been asking the same questions about stablecoins for two years: Is this legal? What’s the capital treatment? What do we tell the examiner? The answers have been scattered across interpretive letters, proposed rulemakings, and the footnotes of regulatory guidance.
We've compiled those answers.
Today I'm publishing Banking Stablecoins: A Regulatory and Operational Framework, a practical guide co-authored with Carl Goss of Hunton Andrews Kurth LLP and Roman Goldstein of Klaros Group. Carl is a former OCC examiner who has advised banks on digital asset strategy since before it was fashionable. Roman is a former Fed innovation policy analyst who shaped the supervisory framework for digital assets. Together we've worked through the principal regulatory domains that a bank needs to navigate before building a stablecoin product.
The paper is written for the risk officer, general counsel, and chief innovation officer at a regional or community bank.
In the paper, we cover:
- Stablecoin issuance rules under the GENIUS Act
- Use cases and business models for bank-provided stablecoin products
- Balance sheet models for banks dealing in stablecoins
- Analysis of regulatory treatment for capital, liquidity, UCC, consumer protection, and more
- Comparison of stablecoin to deposit tokens
- Regulatory considerations for deposit tokenization
Read the Paper
The full paper is available at omnia.financial/stablecoin-paper.
If you have questions about how these frameworks apply to your institution's specific situation, reach out at davis@omnia.financial. We're happy to talk through it.