Payments

Letters and Testimonies

Letters to Regulators

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Title
Recipient
Date
06/30/25
05/30/25
12/16/24
Consumer Financial Protection Bureau08/01/24
06/11/24
Federal Reserve05/11/24
Basel Committee on Banking Supervision03/28/24
Federal Reserve, Justice Department, Treasury Department03/22/24
BIS Committee on Payments and Market Infrastructures02/28/24
Letter to Regulators01/30/24
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Testimony

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Title
Committee
Presenter
Date
House Financial Services CommitteeWritten Statement04/01/25
Senate Banking CommitteeWritten Statement03/12/25
House Subcommittee on Digital Assets, Financial Technology and InclusionWritten Statement09/13/23
Senate Banking CommitteeWritten Statement02/13/23
Senate Banking CommitteeWritten Statement07/28/22
House Financial Services CommitteeWritten statement05/25/22
Senate Banking Hearing02/15/22
House Financial Services CommitteeWritten statement02/08/22
Senate Banking CommitteeWritten Statement12/14/21
House Financial Services CommitteeWritten statement12/07/21
HSFC09/29/20

Payments News

New BIS report raises concerns with stablecoins

June 25, 2025

The Bank for International Settlements said that while tokenization can enhance efficiency and open new possibilities in cross-border payments and securities markets, stablecoins pose a risk to financial stability and monetary sovereignty without regulation.

Details: In a special chapter of BIS's Annual Economic Report 2025, the global institution said:

  • Stablecoins perform poorly when assessed against three tests for serving as the mainstay of the monetary system.

  • The circulation of stablecoins without issuer oversight raises concerns about their use for financial crime.

  • Stablecoins fare poorly on singleness and elasticity, lacking the settlement function provided by central banks, trading at varying exchange rates, and imposing a cash-in-advance constraint.

  • There is an inherent tension between stablecoins’ promise to always deliver par convertibility (i.e., be truly stable) and the need for a profitable business model that involves liquidity or credit risk.

  • If stablecoins continue to grow, they could pose financial stability risks, including the tail risk of fire sales of safe assets.

  • Bank-issued stablecoins may introduce new risks, depending on their legal and governance arrangements.

Congressional Debate: As Congress continues to consider legislation to establish a regulatory framework for currently unregulated stablecoins following last week’s Senate passage of the GENIUS Act, ICBA this week urged House Financial Services Committee Chairman French Hill (R-Ark.) to ensure any measure considered by the House includes guardrails against negative economic consequences that would result from community bank disintermediation.