1/ We’ll be posting throughout the day with our thoughts on the #crypto bill released today by @SenLummis and @SenGillibrand, the Lummis-Gillibrand Responsible Financial Innovation Act
@SenLummis @SenGillibrand 2/ #LummisGillibrandBill would create definitions for #digitalasset, #virtualcurrency, #paymentstablecoin, #smartcontracts
3/ #LummisGillibrandBill would authorize depository institutions to issue payment stablecoins
4/ Under #LummisGillibrandBill, many digital assets would be treated as “ancillary assets,” and presumed to be commodities rather than securities
5/ Ancillary asset issuers would be subject to SEC disclosure requirements under #LummisGillibrandBill
6/ #LummisGillibrandBill would direct the SEC to issue guidance providing how custody requirements may be satisfied for digital asset securities
7/ #LummisGillibrandBill would grant the CFTC spot market jurisdiction over all fungible digital assets that are not securities, including ancillary assets
8/ #LummisGillibrandBill would allow digital asset exchanges to register with the CFTC to conduct trading activities
9/ #LummisGillibrandBill would clarify the bankruptcy treatment of digital assets held by intermediaries
10/ Payment stablecoins issued by a bank would be classified as identified banking products under the #LummisGillibrandBill, which would exempt them from certain provisions of the federal securities and commodities laws
11/ Consumer protection rules in the #LummisGillibrandBill would require digital asset providers to disclose, e.g., asset treatment in bankruptcy, risks of loss, fees
12/ #LummisGillibrandBill would impose a 100% HQLA reserve requirement on all payment stablecoin issuers
13/ #LummisGillibrandBill would require all issuers of payment stablecoins to issue monthly public disclosures on value of assets backing the stablecoin
14/ #LummisGillibrandBill would direct the CFTC and SEC to develop a proposal for digital asset SROs
15/ #LummisGillibrandBill would permit an interstate sandbox approach for innovative financial products
16/ #LummisGillibrandBill would expressly authorize the OCC to grant a special charter to national banks engaged exclusively in payment stablecoin activities
17/ #LummisGillibrandBill would establish tailored holding company supervision for depository institutions operating under a special DI charter for stablecoin issuers
18/ A key priority of federal policymakers has been the regulation of #stablecoins. We’ve compared the #LummisGillibrandBill stablecoin provisions to those of several other legislative proposals. 
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