Articles
Insight
'Skinny Master' does not change legal eligibility
Oct. 22, 2025
Before you get too excited about the "skinny" master account (aka payment account) proposed by Fed Governor Waller, it's important to read his words carefully. Waller repeatedly stressed that the...
Insight
Enthusiasm for AI in GR
Oct. 20, 2025
I know I can get enthusiastic about the promise of AI for policy work. But even I was surprised by the level of energy and curiosity at our AI Tools for Public Policy panel during last week’s...
Insight
How GENIUS Act opens doors for uninsured banks
Sept. 24, 2025
Controversy is clustering around the GENIUS Act provision granting state depository institutions national money transmission and custody powers when acting through a stablecoin issuer subsidiary....
Insight
How long will GENIUS Act applications really take?
Sept. 17, 2025
How long will a GENIUS Act application really take? If you just look at the law's timelines and make some reasonable assumptions, you can be forgiven for estimating "somewhere between 120-180 days."...
Insight
Banks will not lose customers to stablecoins, but to apps that use them
Sept. 15, 2025
Bank customers won’t switch to stablecoins. They’ll switch to software that uses stablecoins. That’s one reason stablecoins’ impact on bank deposits is so hard to predict. The main drivers aren’t...
Insight
Combining ILC and GENIUS Act applications
Sept. 3, 2025
Combining ILC and GENIUS Act applications is an intriguing possibility for a fintech looking to break out of the sponsor-bank paradigm. In this scenario, the company applies for a new ILC charter...
Insight
The 14 types of GENIUS Act issuer
Aug. 31, 2025
The GENIUS Act purports to create three major types of stablecoin issuer. But by my count, there are at least 14 different forms that a permitted payment stablecoin issuer can take. The 14 forms...
Insight
Structural choices for GENIUS Act issuers
Aug. 29, 2025
Of the myriad structural choices facing a prospective GENIUS Act stablecoin issuer, the most significant is between depository and non-depository options. I see three key differences between these...
Insight
GENIUS Act application window likely will not open until July 2026
Aug. 26, 2025
No one knows exactly when the federal application window for GENIUS Act stablecoin issuers will officially open. But it's hard to see it happening much earlier than the statutory deadline in mid-July...
Insight
Crowdsourcing + AI rulemaking
Aug. 25, 2025
Crowdsourcing + AI is a viable strategy for rulemaking in an era of smaller agency staffs. This seems to be emerging thinking in the Administration. The first sign was the deregulation suggestion...