Thread: The right way to go about deciding how to regulate stablecoins.
Having explained why loose (and misinformed) comparisons with 19th century banknotes are the wrong way to proceed, I thought I'd offer some positive suggestions.
(1) Acknowledge the fact that there are many types of stablecoins, with different underlying technologies and principle uses. It is highly unlikely that any broad-brush regulatory treatment will be appropriate to all.
(2) Stop calling them "money." They are niche exchange media, not generally accepted exchange media. And that is itself not a bad thing so long as national monies are also available.
(3) It follows from (2) that occasional deviations of stablecoins' value from that of underlying standard monies' value is also not bad ipso facto. It's like a pegged fiat currency where the peg isn't perfect. If there's no contractual commitment to absolute stability, so what?
(4) Distinguish between AML KYC, consumer protection, and other "microeconomic" goals of regulation and macroeconomic goals,and make clear which if any a suggested regulation is supposed to achieve.
(5) For macro. (stability) goals, the relative questions are whether regulations are needed to keep a stablecoin from either interfering with the ordinary conduct of monetary policy or to keep it from becoming a source of systemic risk.
(6) In either of these last cases, arguments for regulation should rest of specific arguments about potential macroeconomic risks--arguments that take account of specific stablecoin operating mechanisms
(7) If, for example, the claim is that regulation is keep a run on a stablecoin from posing systemic risks, the argument should show (a) how the specific operating mechanism is in fact vulnerable to runs and (b) how the runs can adversely affect other intermediaries.
(8) A demonstration of the sort described in (7) only works for one set of similar stablecoins. It can't be used to justify like regulation of very different stablecoins.
(9) Conversely, efforts should be made to discover which sorts of stablecoins pose the lowest risks, since one approach to regulation consists of encouraging the use of such stablecoins. Efficient regulation isn't just a matter of prohibiting dangerous options.
(10) I suspect that some stablecoin designs either are or can be made to be macroeconomically _safer_ than conventional, bank-supplied exchange media. For that reason, trying to make stablecoin issuers function like regulated banks should not be a priority.
(11) Item (10) means that any choice among several possible regulatory arrangements should favor those that will permit ongoing stablecoin market innovation over those that might stifle it, other things equal.
Want to write like an academic economist? Here's my sure-fire guide to Standard Econ English.
"Recent." Used with "writings" or "work" in your opening sentence to assure readers that you are au courant, which is to say, determining your subject matter the way herring determine which way to swim.
"The remainder of this paper is structured as follows." Indispensable start of your introduction's final paragraph, which you must include because the preceding paragraphs have somehow failed to do what they're supposed to.
Anti- GZ, cont'd: the rise of national currency (pp. 27ff.) GZ conclude their discussion of antebellum currency by stating that, because that currency violated the NQA (No Questions Asked) principle, the antebellum "community had no money."
As I've already pointed out, regarded as a description of conditions on the eve of the Civil War, is very misleading, in part because there was by then no shortage of official coins, which were undoubtedly national NQA means of exchange.
As for state banknotes were, although discounting cont'd to disqualify them as truly "national" currencies, by the 1860s these discounts tended to be modest. Furthermore, almost all state bank notes were par monies for their "state" communities, if not in some surrounding states.
My Gorton and Zhang critique series continues with a look at their discussion of antebellum U.S. currency (pp. 23ff.) Although their discussion of that history is better than many other recent ones (see alt-m.org/2021/07/06/the…), it is still misleading.
Although GZ recognize that most bank failures back then had nothing to do with "wildcat" banking, they still exaggerate the extent to which antebellum currency was (literally) "subpar."
Just as CZ "cherry pick" by focusing on US currency experience, ignoring what happened elsewhere, they also cherry pick from the diverse US record. I've already noted how they ignore the Suffolk System's successful achievement of a uniform New England currency--a "good" cherry.
Gorton and Zhang's highly eccentric interpretation of pre-Fed banking crises isn't just inaccurate: it's topsy-turvy. And, like many of their paper's historical claims, it is contradicted by a wealth of evidence from other banking systems. 1/2
The _fons errorum_ of this and many of GZ's other mistaken arguments is their assumption that private monies must be 100% backed by reserves or Treasurys, or otherwise fully guaranteed by the state, to be stable and to trade at par.
While such arrangements can contribute to stability, they are neither necessary nor sufficient. Indeed, the Treasurys-backing requirement for national bank notes, for example, was a fundamental _cause_ of instability under the pre-Fed national currency system.
In my last thread on Gorton and Zhang's new working paper, I criticized their criteria, in Table 1 of their paper (p. 5) for selecting among options for regulating stablecoins. Here I turn to the paragraph immediately following that table, which itself calls for a thread.
Here they claim that the option of requiring that stablecoins be 100% backed by reserves or Treasurys "ties two forms of money together at a fixed ratio," thereby making "a shortage of one pf the forms of money" likely.
To illustrate, they point to the currency shortages that plagues the pre-Fed national currency system (1866-1014). They say these were caused by nat'l banks reluctance "to move all the Treasuries to back national bank notes," that this caused deposits to expand instead, and
That makes for a neat segue to my next criticism, concerning GZ's table 1 (p. 5). Here they consider various "Options to Address Stablecoins," asking of each whether it (1) would eliminate runs on stablecoins and (2) would make it unnecessary for their users to scrutinize them.
Based on those assumed goals, they narrow down acceptable options to three: treatment like ordinary banks, 100% reserve (or Treasurys) backing, or replacement w/ CBDC, that is, outright prohibition.