1/ "Even in the face of regulatory threats, #crypto enthusiasts see each development as a step towards mainstream acceptance. So it's no surprise that a new crypto-friendly bank becoming a member of the Federal Reserve would be a headline grab."🤠@AvantiBT businessinsider.com/ceo-crypto-ban…
2/US banking law is confusing but @lailamaidan got it right--@AvantiBT is different--is eligible for BOTH access to Fed's payment system & to become Fed member PLUS has applied for BOTH. (OCC trust banks aren't depository institutions so aren't eligible for payment system access)
3/ I can't think of another industry that is so deposit-constrained: ~$80bn of USD bank deposits supports >$2trn in assets. Our industry has a big single point of failure risk: USD banking access. Plus there's lots of settlement risk in trad banks when they bank #crypto industry.
4/ Why? bc big differences in settlement timing & finality btwn #crypto & USD pose safety & soundness risks when trad (leveraged) banks service crypto. Payment system risk too--if a trad bank is overdrawn at the Fed + its #crypto activities trigger a run, pymt system takes a loss
5/ This is why #Wyoming#SPDI banks are structured as they are--among other reasons, they're designed to minimize payment system risk (and not to become overdrawn at the Fed), so that #crypto & USD banking can be safely & soundly connected. LOTS of details behind all this.💡
6/ Last night I saw @jimcramer talk on @CNBC abt a mega bank issuing an "honest #stablecoin"--suggesting the bank may need to issue it in a new stand-alone subsidiary (separate from its traditional deposit business). He's right but I'm not sure if he realizes the big reason why.
7/ It's true that #stablecoin-issuing banks need to be ring-fenced from trad (leveraged) banks--too much bank run + payment system risk otherwise. Vast majority of trad banks settle books & records only 1x/day but stablecoins settle in minutes w/ irreversibility. Easy to see prob
8/ And it'd ESPECIALLY be a problem if such big issues were to hit all at once at a GSIB (global systemically important bank). This is why I've said for yrs #crypto activities shld be ring-fenced in special-purpose banks (ie, stand-alone banks or ring-fenced subs of trad banks).
9/ Of course, the mega banks want the #stablecoin market all to themselves & their DC lobbyists have been attacking #crypto-native companies, trying to block all of us out (including those of us that have bank charters & agreed to be subject to the exact same rules they are).
10/ The next few weeks will tell a lot about the policy direction in the US, as @lailamaidan's story says, as the Fed's #CBDC paper & President's Working Group (#PWG) #stablecoin recommendations are on track to be released. /end
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1/JUST FINISHED the first of my series of speeches this month to mainstream audiences about #bitcoin/#crypto--this one was to @actl, annual meeting of American College of Trial Lawyers. Multiple Supreme Court justices usually in audience. Two key themes:
2/ First, I recommended swift clarification of legal status of #digitalassets so US courts aren't clogged w/ disputes in this $2trn industry due to murky laws (incl swift passage of draft UCC Article 12, or even early adopting it). It's on agenda for @uniformlaws mtg on Nov5-6.
3/ #Wyoming led charge to make #blockchain tech "backwards compatible w/ US legal system"--draft UCC Art. 12 (similar to WY law) was already early-adopted by AR, NE & TX. We're seeing increasing litigation due to murky laws--not only clogs courts but consumer fairness issues too.
1/ THIS IS WHERE WE ALWAYS THOUGHT the #stablecoin regulatory direction would go, which is why @AvantiBT chose to get a bank charter. Anything that touches the USD financial system was always going to fall w/in the Fed's purview, directly or indirectly, esp once it became big.
2/ Plus it makes sense policy-wise. Nonbank #stablecoin issuers gum up the #repo mkt by siloing T-bills & other Level 1 high-quality liquid assets (the repo mkt already finds these assets too scarce). If stablecoin issuers are banks, tho, dormant Fed reserves can be used instead.
3/ Details on the above point are here👇. The v high velocity of #stablecoins comes from their superior tech vs trad payment systems, not from leverage. Traditionally, monetary velocity came from leverage. But thanks to stablecoins it no longer needs to.💪 cato.org/cato-journal/s…
1/ @NYtimes story on #crypto/#banking deserves a thoughtful reply. Issue isn't black & white: anti-crypto forces try to paint us all w/ a broad brush. Bad actors deserve to be called out, but the article ignores fact that regulatory-compliant firms exist. nytimes.com/2021/09/05/us/…
2/ First--@ericliptonnyt/@el72champs you got a fact wrong & it deserves a correction. #Wyoming’s special bank charter doesn't allow “cryptocurrency deposits.” “Deposit” has a v specific meaning in banking: banks can only take deposits in fiat money (US$)--not in crypto. Pls fix.
3/ That’s a key distinction. Regulated banks can provide CUSTODY services for #crypto (like for securities) but CAN’T take deposits in ANYTHING except money. Article misses that critical point--it’s a firewall protecting Fed's payment system from exposure to anything other than $
1/ TODAY @AvantiBT CONFIRMED A REPORT in today's @WSJ that it filed an application to become a Federal Reserve member bank. 💪 Here are links to Avanti's statement & the WSJ story: wsj.com/articles/crypt…
2/ This means @AvantiBT formally submitted to what it had already informally accepted--namely, the very same regulatory capital, compliance and supervisory examination standards that apply to traditional banks.
3/ It also means @AvantiBT is seeking federal supervision directly by the Fed itself (in addition to Avanti's existing regulator, #Wyoming Division of Banking). Avanti's Fed membership application is distinct from its prior application for payment system access (filed Oct 2020).
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
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”)