1/ ~FIVE YEARS AGO, I first said #bitcoin cld take down a GSIB (global systemically important bank)--NOT because of anything wrong w/ Bitcoin, but bc the banks just aren't set up to handle an asset that settles in minutes & is irreversible. @ChrisBrummerDrrollcall.com/podcasts/finte…
2/ If banks are going to start owning #bitcoin/#crypto on their books(ie, not just being custodians like w/ stocks), banks need special rules to deal w/ the huge differences in settlement terms. Banks use systems set up ~40yrs ago (esp in US),most of which reconcile only 1x/day😱
3/ Again-issue is w/ banks' IT & operational systems, not w/ #Bitcoin (which I consider the most significant financial technology invention of human history. Yep, really💪). In this @ChrisBrummerDr podcast w/ former Fed Governor Dan Tarullo, we discuss how bank capital rules work
4/ We also discuss the @BIS_org Basel III capital proposal for banks to require 1:1 equity capital for all #crypto held on their books (except certain #stablecoins), why #bitcoin will probably never have central clearing & why all custody banks have elevated operational risk.
5/ We end up pretty much agreeing that trad banks shouldn't own #bitcoin/#crypto (tho custody is OK) until special rules are in place. And, gee, thankfully there already is a bank charter with such special rules (the #Wyoming#SPDI), & it's already available to the Fed today.🤠
6/ Tarullo also talks about the history of the decision to keep money market funds (MMMFs) outside of the banking system--since then, the Fed has had to bail out MMMFs 3x & the commercial paper market 4x. It doesn't want to face bailouts of anything related to #crypto in future.
7/ The information frontier in #bitcoin & #crypto is not on #WallSt. (Gee, how many Bitcoin Core devs work for large banks??🤔)
PayPal has been subject of vigorous debate for yrs abt bringing fintech activities inside banking system--but #stablecoins are now 3x size of PayPal!
8/ Will #stablecoins finally trigger resolution of decades-long debate on whether to start chartering fintechs as banks? US didn't charter ANY new banks in the decade following 2008 crisis, so #fintech activities proliferate outside of Fed. Seems it's all coming to a head now.🧐
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1/ THREAD ABT REGULATORY NEWS in #crypto, which I’ve been chronicling on twitter since April. Seems crackdown has begun. I dunno how it'll turn out but:
* it won't impact #BTC#ETH etc directly. Base layers will keep addin' blocks
* it'll impact intermediaries & US$ access points
2/ Today was a key event that few in #crypto were probably watching, but it REALLY matters: the comment period ended for the Fed’s proposed payment system access guidelines. See comment letters here (including @AvantiBT’s 18-page tome--awaiting upload): federalreserve.gov/apps/foia/View…
3/ Why does it matter? Fed guidelines are partly aimed at #crypto (despite not mentioning crypto even once). Given what’s happening w/ US$ #stablecoins, the guidelines are esp relevant (see WSJ story last wk-FSOC wants Fed to regulate stablecoins per “ppl familiar w/discussion”)
1/ ANOTHER STABLECOIN SPEECH by ex-BOE/BOC head Mark Carney--he was surprisingly direct:
* #stablecoins shld have access to central bank's balance sheet;
* "existing bank-based payment rails are expensive, even if those costs aren't visible to consumers" bis.org/events/acrocke…
2/
* "banks are a means to an end, not ends in themselves, & they'll have to adapt to a much more competitive environment" [WOW, SPICY]
* "any systemic pymt system must be overseen by a central bank & have final settlement option in public money"
3/
* "regulatory model for #stablecoins must offer equivalent protections to commercial bank money" to include:
-legal claim paid in fiat upon demand
-capital rqmts
-liquidity rqmts
-central bank access terms
-backstop if failure
1/ IT MAY SURPRISE YOU that, as a #bitcoiner, I think @BIS_org's proposed 1:1 capital rqmnt for #bitcoin is TOO LOW & view banks entering bitcoin trading as bad for banks & bitcoin's price volatility. The problem isn't Bitcoin--it's the banks.@ForbesCrypto forbes.com/sites/caitlinl…
2/ @BIS_org's capital proposal completely missed biggest issue w/ banks holding #bitcoin on-balance sheet: settlement risk. Traditional banks are simply not set up operationally or technologically to hold on-balance sheet assets that settle in minutes w/ irreversibility.
3/ Many spoke out that the 1:1 capital rqmt was too high. But the opposite is true. The Basel III framework isn't set up to assess settlement risk. It doesn't have to, bc there are all kinds of operational fault tolerance mechanisms built into traditional financial markets.
1/ NOT MUCH HAS BEEN WRITTEN yet abt this #stablecoin paper by @bankofengland June 7. I'm just getting to it. Big deal.🧐"HMT propose to bring systemic #stablecoins into BOE's regulatory remit, in line w/ its responsibilities for systemic payments systems" bankofengland.co.uk/paper/2021/new…
2/ Yep, I've warned this is an issue central bankers have w/ #stablecoins issued by non-banks:
"A large-scale displacement of commercial bank money by new forms of digital money cld mean a higher fraction of money in economy backed by high-quality liquid assets (HQLA)."
3/ "Commercial banks would have to adapt their balance sheets in response to deposits leaving the banking system...the Bank may wish to limit migration, so financial system could adjust to the presence of new forms of digital money in an orderly fashion." Oh boy, BOE went there.
"Article 7: Every economic agent must accept #bitcoin as payment when offered to him by whoever acquires a good or service."
"Article 13: All obligations in money expressed in USD, existing before the effective date of this law, may be paid in #bitcoin."
"Art 14: ...the State will guarantee, thru the creation of a trust at the Banco de Desarrollo de ElSalvador, the automatic & instantaneous convertibility of #bitcoin to USD necessary for the alternatives provided by the State in Art 8."
1/ I'M PSYCHED to announce new advisors for @AvantiBT, helping design & build services for traditional institutional investors & corporate treasurers, incl @Ford's former treasurer, Neil Schloss, Ford's ex-treasury IT head Bob Cullinan & ex-@blackrock managing director Tim Keefe.
2/ "I see @AvantiBT’s solutions as potential game changers for corporate treasurers."--Neil Schloss, ex-Treasurer of @Ford. "Avanti is building API-based payment solutions...to solve day-to-day problems by seamlessly integrating payments processes w/ treasury cash mgmt systems."
3/ It's a thrill to bring these 3 accomplished execs into @AvantiBT's fold. Tim Keefe is one of the smartest portfolio managers w/ whom I've ever worked, dating back to 1997. He's now "all-in" on #bitcoin & a founder at @LedgerstatC & partner at @OffTheChainCap.