Legislation for Stablecoins Should Honor the Dual-Banking System

The current dual-banking system in the United States is complex and far from perfect, as there is an overlap between state and federal jurisdiction when it comes to regulating banks. State-chartered banks that are also members of the Federal Deposit Insurance Corporation and/or the Federal Reserve System are subject to additional federal supervision. However, for stablecoin issuers, who provide a payment tool in the form of tokens pegged 1:1 to the U.S. dollar, federal bank supervision may not be necessary.

Stablecoin issuers do not offer traditional banking services, but rather a means of facilitating payments using digital tokens. Therefore, subjecting stablecoin issuers to the same level of federal oversight as traditional banks may not be the most effective approach. As the popularity of stablecoins continues to grow, regulators will need to evaluate the most appropriate regulatory framework to ensure consumer protection and financial stability.