Payments

Letters and Testimonies

Letters to Congress

Title Recipient Date
Joint Trades Letter Opposing Credit Card Price Control Bill Sen. Josh Hawley 09/20/23
Letter on CBDC Bills Ahead of House Markup House Financial Services Committee 09/19/23
ICBA Letter on House Stablecoin Legislation Ahead of Markup House Financial Services Committee 07/19/23
Joint Financial Sector Letter Opposing Credit Card Routing Bill House, Senate Leaders 07/14/23
State Association Joint Letter Opposing Credit Card Competition Act House, Senate 07/11/23
ICBA Letter on Revised House Stablecoin Draft Bill House Financial Services Committee 06/13/23
Joint Letter Opposing Reintroduction of Credit Card Competition Act Senate, House leaders 06/09/23
Letter on Revised Stablecoin Draft Legislation House Financial Services Committee 05/05/23
Letter Offering Community Bank Perspective on Stablecoin Legislation House Financial Services Committee 04/19/23
Support for House Central Bank Digital Currency Anti-Surveillance State Act Rep. Tom Emmer 03/08/23
Letter on ICBA Lame Duck Agenda Senate, House 11/17/22
State Letter Opposing Credit Card Competition Act House, Senate 10/11/22
Joint Letter Opposing Marshall-Durbin NDAA Amendments Senate 10/04/22
Joint Letter on Credit Card Competition Act House 09/27/22
Letter Opposing House Interchange Bill House 09/21/22
ICBA Letter Opposing Credit Card Competition Act Senate 08/31/22
Letter on Stablecoin Legislation House Financial Services Committee 07/22/22
Joint State Trades Letter to the Senate Judiciary Committe Interchange Hearing Senate Judiciary Committee 05/04/22
Joint Letter for Senate Interchange Hearing Senate Judiciary Committee 05/02/22
Support for Senate CBDC, FedAccount Bill Sens. Cruz, Braun, Grassley 04/04/22
Support for House CBDC, FedAccount Bill Rep. Tom Emmer 04/04/22
Joint Trades Credit Interchange Cap Letter Congress 07/27/21
Hill Payments Charter Letter 116th Congress 10/15/20
Hill Payments Charter Letter 9.29 U.S. House Task Force on Financial Technology 09/29/20

Letters to Regulators

Title Recipient Date
Comments on Basel Cryptoasset Standard Amendments Basel Committee on Banking Supervision 03/28/24
Freedom of Information Act Request on CBDC Authority Federal Reserve, Justice Department, Treasury Department 03/22/24
Joint Trade Statement on ISO 20022 Standards BIS Committee on Payments and Market Infrastructures 02/28/24
Disclosure of Cryptoasset Exposures Letter to Regulators 01/30/24
ICBA Comment Letter for FinCEN Cryptocurrency Mixer Proposal FinCEN 01/23/24
Joint Extension Request on Fed Debit Card Interchange Price Cap Federal Reserve 11/27/23
Comments on Proposed Tax Treatment of Digital Assets IRS 11/13/23
Joint Trades Letter on Reg II Board Meeting Federal Reserve 10/20/23
Response to IOSCO DeFi Policy Recommendations IOSCO 10/18/23
Joint Letter on Mortgage Rates White House, Treasury Department 10/12/23

Testimony

Title Committee Presenter Date
Statement for House Hearing on Central Bank Digital Currency Risks House Subcommittee on Digital Assets, Financial Technology and Inclusion Written Statement 09/13/23
Effective Regulation of Crypto Assets Senate Banking Committee Written Statement 02/13/23
Statement for Senate Crypto Hearing Senate Banking Committee Written Statement 07/28/22
Hearing Statement on Central Bank Digital Currency House Financial Services Committee Written statement 05/25/22
Enhanced Regulation of Digital Assets Will Promote Responsible Innovation Senate Banking Hearing 02/15/22
Statement for House Hearing on Stablecoins House Financial Services Committee Written statement 02/08/22
Statement for Senate Stablecoin Hearing Senate Banking Committee Written Statement 12/14/21
Statement for House Hearing on Digital Assets House Financial Services Committee Written statement 12/07/21
ICBA Statement for HFSC Fintech Hearing 9-29-2020 HSFC 09/29/20

Payments News

OCC conditionally approves Paxos bank charter

April 26, 2021

The OCC conditionally approved the ICBA-opposed trust bank charter application from Paxos, a cryptocurrency platform.

Charter: Paxos applied to charter Paxos National Trust. The trust bank would offer custody, fiduciary, and “know your customer” services; custody and management of stablecoin reserves; and “other cryptocurrency services.”

ICBA Position: In a joint letter earlier this year, ICBA and other groups said more information is needed about the applications from Paxos and BitPay. The groups cited vague language in the applications, said they don’t appear to meet trust bank fiduciary requirements, and urged the OCC to postpone the application process and provide more information.