TDC Statement on Clarity Act Draft as Senate Vote Approaches

Today’s draft is a meaningful step toward the Senate vote on the Clarity Act we’ve been calling for. We look forward to reviewing the latest, and we will provide our members’ feedback on how the bill may still be improved as it moves forward.

Our optimism has never wavered. Through every round of negotiation, we’ve believed that Congress would deliver the market structure framework this industry and everyday consumers need. Now is our best chance for durable market structure law to allow America to be the global leader in digital assets. We’re encouraged, and we’re ready to keep working until the bill reaches the President’s desk.

For any inquires, please contact TDC at press@digitalchamber.org.

State Spotlight: Anthony Apollo of Wyoming 

What or who made you interested in the digital assets, blockchain, and emerging technology space?

Through my advisory work at several GSIBs in the wake of the 2008 Global Financial Crisis and subsequent passage of the Dodd-Frank Act, I saw many legacy systems at traditional institutions breaking in real-time. Concurrently, I was introduced to Bitcoin and Ethereum. A unified, immutable, public ledger and the concept of “programmable money” simply made more sense in a digitally connected world. I made the full-time pivot to blockchain work in 2017 and have been building in the space since.

What is driving your state’s approach to digital assets and emerging technology right now?

A desire to fortify Wyoming’s position as the leading state for cryptocurrency, blockchain, and digital asset legislation. Since 2016, over 80 bills on these topics have been proposed, with more than 50 enacted into law. There is also a drive to further embed digital assets into government operations for increased efficiency, reduced costs, and enhanced transparency. This will require a multi-agency effort to prioritize and publicize the initiatives enabled by the state’s permissive regulations.

How do you see digital assets impacting your constituents or local communities directly?

Our agency endeavors to put real dollars back in the pockets of Wyoming’s citizens. Take for example testimony by Joel Schell, Converse County Treasurer. In a recent Commission meeting, Treasurer Schell testified that his office took in $3.4M in tax remittances, but his constituents paid $70,000 in credit card fees to facilitate those payments. Using the Frontier Stable Token would lower these costs to fractions of a cent per transaction.

What advice would you give to other states looking to engage in this space?

Find champions in your legislature and executive branch to support digital asset initiatives for the long-term. Wyoming has been fortunate to have strong and consistent leadership through its Select Committee on Blockchain, Financial Technology, and Digital Innovation Technology – the body responsible for drafting the key topical legislation. Further, Governor Mark Gordon has presided over the majority of bills enacted in Wyoming and currently serves as the Chairman of the Commission.

Where do you see the biggest opportunity for blockchain or digital assets in your state?

In January 2026, Wyoming launched the Frontier Stable Token – the first fiat-backed and fully-reserved stable token to be issued by a public entity in the United States. Dollars received by the Commission for the purchase of “FRNT” are invested in short-duration U.S. Treasuries and repurchases thereof. Both of these instruments bear interest that is collected by the state and swept into Wyoming’s school foundation program on a quarterly basis. We consider FRNT a public good for Wyoming.

About Anthony Apollo:
Anthony Apollo was appointed as the inaugural Executive Director of the WY Stable Token Commission in September 2023. Director Apollo brings his experience in both traditional finance (KPMG, EY) and digital assets (ConsenSys, Rensa) to the development of the first fiat-backed, fully-reserved stable token issued by a public entity in the U.S.

TDC Challenges Illinois Crypto Tax in Court

To address the unfair tax burden that would be imposed under the Digital Asset Tax Act included in the recent Illinois state budget, The Digital Chamber (TDC) filed a lawsuit today in Sangamon County asking the court to halt the last-minute tax provision slipped into the state’s annual spending bill. The suit seeks to stop the tax from adversely affecting TDC’s members, who are already incurring costs trying to comply with the new tax ahead of its expected January 2027 effective date.

The lawsuit argues that no one should be taxed differently because of how ownership is recorded or transferred. Put simply, this tax discriminates against people who transact in digital assets. This tax is universally applied, regardless of whether the investor realizes any gain, or whether ownership is even being transferred. This expansive provision would affect any tech transaction, including potentially AI and cloud-based applications.

“Today we are asking the courts to protect consumers and our members and stop this unfair tax in Illinois. Taxes should be carefully considered, not only for the revenue they produce but for the fairness of those being taxed. That was not the case here, as the provision slipped into legislation the night before the bill’s final consideration,” said Cody Carbone, TDC’s CEO.

From here, the court’s rules provide a window for more groups to join this lawsuit. To inquire about joining this fight, contact policy@digitalchamber.org to learn more.

TDC Response: FDIC’s Requirements for Stablecoin Issuers

The FDIC has the opportunity to create a strong framework for payment stablecoins, as long as the agency’s rules remain faithful to the language and intent of the GENIUS Act. Our core message in The Digital Chamber’s cautionary feedback to the FDIC is simple: do not add requirements Congress did not include, create inconsistent standards across regulators, or turn the stablecoin framework into a broader bank-style capital, deposit-allocation, or anti-innovation regime. You can read our full letter of recommendations HERE, but below are a few of the notable recommendations from our submission:  

A quick summary of several key points the FDIC should address: 

  1. The FDIC should harmonize its definitions and regulatory standards. 
  • The Office of the Comptroller of the Currency (OCC), Federal Reserve, and National Credit Union Administration (NCUA) should ensure that similarly situated issuers are not treated differently based solely on their primary regulator. 
  • Similarly, complex issues around tokenized deposits, deposit tokens, and the boundary between bank deposits and payment stablecoins must be addressed through harmonized rules and guidance across regulators, rather than resolved indirectly through this FDIC proposal. 
  1. We recommended changes to several definitions: 
  • The FDIC’s proposed definition of “insured depository institution” may be too narrow and could unintentionally exclude certain federally supervised banking institutions, including certain U.S. branches of foreign banks, from serving as reserve counterparties.  
  • Additionally, we recommended refining the definitions for “eligible financial institution,” “public distributed ledger,” “smart contract,” and “payment stablecoin holder.”  
  1. Expanding issuer obligations to downstream stablecoin holders with no direct relationship to the issuer did not make sense. As such, we emphasized that regulatory obligations should correlate with direct customer relationships, and that downstream users should be protected through disclosures, redemption rights, and reserve requirements. 
  1. We urged the FDIC to allow stablecoin issuers to engage in activities related to issuance, redemption, reserve management, custody, smart contract deployment, blockchain infrastructure, cross-chain functionality, and operational risk management. 
  1. Our response supported reserve identification, traceability, segregation, audits, and redemption protections that make sense.  
  • However, we noted that mandating a single legal structure, custody model, Simplified Payment Verification (SPV), or reserve management approach that does not align with that recommendation. This will give issuers flexibility to meet statutory requirements through different legally effective structures. 
  1. Finally, we noted that adding capital-like reserve buffers, standardized haircuts, automatic liquidation requirements, or rigid caps beyond the GENIUS Act was concerning. The statute already establishes a strict reserve framework, and additional requirements could reduce liquidity and limit competition. 
     

Overall, the strong supervision, full-reserve backing, redemption rights, transparency, and risk management in the NPRM all form a sensible implementation proposal aligned with Congressional intent. Our repeated stance in our response letter is that inconsistent treatment across agencies and requirements that would undermine the competitive and innovative framework Congress intended in passing the GENIUS Act should not be a part of the final version of the FDIC rules. 

Read our full response here.

One Year of the GENIUS Act  

One year ago, on July 18, 2025, President Trump signed the GENIUS Act into law, transforming how stablecoins (digital assets pegged to the U.S. dollar) are regulated in the U.S.  The law established a clear federal framework for stablecoins and became part of history as the first major piece of crypto legislation ever signed into law in the U.S.  

The GENIUS Act requires stablecoin issuers to maintain 1:1 reserves in safe assets such as U.S. dollars and short-term Treasuries, publish monthly reports, and comply with anti-money laundering rules. The trust that comes with knowing there is strong federal oversight for stablecoins has been a key unlock to the growth of the asset class. 

The Results 

When the rules became clear, people began building. Major companies took notice almost immediately; Visa, Mastercard, J.P. Morgan, and more integrated or announced stablecoin payment products following the law’s passage. 

  • The global stablecoin market has reached $315 billion in market capitalization in 2026, more than 50% growth from the $206 billion market cap at the beginning of 2025.  
  • Annual global transaction volume surged to nearly $35 trillion in 2025, a figure that rivals major credit card networks.  
  • Real-world stablecoin payments, including businesses paying suppliers, families sending money home, people buying goods, and more, have doubled in a single year to $390 billion. 

Beyond our Borders 

The ripple effect from Washington went global; regulators everywhere watched the U.S. draw clear lines and started drawing their own. 

Stablecoin adoption has been particularly transformative in Latin America. As detailed in Latin America’s Surge in the Global Race to Adopt Stablecoins, the region has become a global leader in stablecoin usage, driven by people seeking to protect their savings from inflation, send remittances cheaply, and access dollar-denominated accounts without a U.S. bank. This effectively turns the citizens in those countries into buyers of U.S. Treasuries and depositors into U.S. bank accounts. The GENIUS Act’s clear framework accelerated this by giving international users and issuers confidence that dollar-backed stablecoins were built on solid ground. 

  • Australia introduced stablecoin legislation in late 2025 and adopted it in April 2026, treating stablecoins as regulated payment products and requiring compliance with standard Australian Securities and Investments Commission (ASIC) regulations. 
  • The EU’s MiCA regulation paved the way for licensed euro-backed stablecoins; Decta’s 2025 report noting that monthly transaction volume rose 899% after MiCA’s rollout. 
  • The Asia-Pacific region is racing to be a hub for regulated digital finance, with frameworks such as Hong Kong’s Project Ensemble, South Korea’s Capital Markets and Electronic Securities Acts, Singapore’s Project Guardian, and more. 
  • Stablecoins now account for roughly 43% of all crypto transaction volume in Sub-Saharan Africa, where people use dollar-pegged digital assets to protect their savings from local-currency inflation. 
  • The Bank of England in the UK revised its pound sterling stablecoin proposal, eliminating a £200,000 limit on individual holders and raising the issuance cap to £40 billion.  

The Takeaway 

Clear rules don’t slow innovation down. They speed it up. Before the GENIUS Act, banks and institutions often wouldn’t touch stablecoins for fear that investments would be lost to shifting regulatory winds. And developers couldn’t build products if they didn’t know whether those products were legal. 

When the U.S. defined the rules of the road, the market responded, and that’s exactly why finishing the job with a market structure bill like the Clarity Act matters now. The GENIUS Act addressed the questions surrounding stablecoins, but the U.S. has yet to clearly define where Bitcoin, Ethereum, and thousands of other digital assets fit within our regulatory system.  

We are closer than ever to market structure rules of the road. The House passed a version of a market structure bill last year. The Senate Banking Committee advanced its portion of the bill in May 2026, just months after the Senate Agriculture Committee passed its portion of the bill. Negotiations are actively blending those bills, so the full Senate can continue pushing the bill towards the President’s desk. 

One year in, the lesson of the GENIUS Act is clear: America leads when it sets standards. The world follows when we do. Now is the time to build on that momentum and set the standard for market structure and asset control. Done right, the rule can support effective enforcement while giving responsible PPSIs the clarity they need to build in the United States. 

Prediction Market Monday: More Than One Simple Market

Most people think of prediction markets as simple yes-or-no predictions on whether an event will occur. In reality, these markets are far more complex. They include a variety of contract types, market designs, and even different forms of currency. Below, we break down the main types of prediction markets and explain their purposes.

Contract Types

There are three main types of contracts: binary, index, and spread. Binary contracts are the most common and well-known. For these contracts, traders make yes or no trades on their predicted outcome of an event. This contract can help to show the probability of an event occurring based on market expectations. For index contracts, the payout varies continuously based on the value of a numerical outcome. A common example is the percentage of votes Trump receives in the presidential election. Index contracts show the market’s expectation of the value, mean, of the event with investors split into buckets of potential outcomes. Lastly, spread contracts are binary contracts where a person can invest in a specific event outcome both occurring and exceeding a certain threshold and the cutoff. The profit or loss would deviate based on how close the trader got to the actual outcome. An example of this type of contract is that President Trump will win 66% of the popular vote. Spread contracts show the market’s expectation of the median. This contract type rewards the forecasting accuracy of a trader over mere direction.

Market Design

The type of market design used by a prediction market impacts the liquidity, distributions of winnings, and capital choices. Continuous double-action design is similar to the stock market, as it matches buyers and sellers when the bid and asking price align. The market maintains a ledger to catalog the trades to ensure all contracts are correctly paid out. This style of market is conducive to high-activity markets with frequent trading and allows people to move in and out of investment positions based on the current market price. This peer-to-peer style can often be supplemented by automatic market makers, who can act as counterparties to both sides of trades, while making money by arbitraging different market values and taking fees on spreads. This approach helps provide liquidity in markets where there are not enough buyers or sellers at a given time, ensuring that participants can virtually always find a willing buyer or seller at around the then-current market prices. Pari-mutuel payouts occur when all investments are pooled together into one pot and then are divided out amongst the winners in proportion to the size of their investment.

Currency

The most common type of currency used in prediction markets is real currency, defined as actual assets or money. It is typically used because it incentivizes traders to make accurate predictions. More recently, some markets have begun using platform-specific tokens or coins, where payouts or incentives are awarded based on the number of tokens earned. There are advantages to using platform-specific tokens over real currency, as they lower the barrier to entry and can increase participation and liquidity.

If you have any questions, please reach out to policy@digitalchamber.org. 

Stablecoin Rules Must Match How Stablecoins Actually Work 

The Digital Chamber submitted a comment letter to FinCEN and OFAC regarding their proposed rule on AML/CFT and sanctions compliance program requirements for permitted payment stablecoin issuers. 

Bringing permitted payment stablecoin issuers, or PPSIs, into a clear BSA/AML framework helps consumers feel confident, helps firms do their part to protect the U.S. financial system and support law enforcement. 

At the same time, TDC urged FinCEN and OFAC to clarify the final rule so it reflects how payment stablecoins actually operate. The key point is simple: issuing a payment stablecoin is not the same as intermediating every transaction in which that stablecoin is later used. 

Why It Matters 

Payment stablecoins can strengthen U.S. payments, expand access to dollar-denominated digital value, and support responsible innovation. The current proposed rules could create obligations that no issuer can realistically meet. 

TDC’s letter focuses on several core points: 

  • PPSIs should be responsible for their own direct activities, such as issuance, redemption, custody, hosted wallet services, or other customer-facing services. 
  • PPSIs should not be required to monitor, report on, or serve as the compliance intermediary for all secondary-market activity merely because they issued the stablecoin. 
  • Recordkeeping, Travel Rule, SAR, and sanctions obligations should apply to the entity with the customer relationship, transaction role, custody, control, or legal ability to act. 
  • Blockchain analytics, digital identity, ecosystem monitoring, and AI-enabled tools can improve compliance, but they should not create broad secondary-market surveillance duties for PPSIs. 
  • FinCEN and OFAC should provide clearer guidance on when PPSIs must block, freeze, reject, seize, burn, or otherwise prevent transfers. 
  • Regulators should account for downstream risks to innocent users when stablecoins are frozen, seized, or burned inside decentralized protocols, liquidity pools, automated market makers, or other shared on-chain systems. 

TDC’s Take 

TDC supports strong AML/CFT and sanctions compliance for stablecoin issuers. But compliance obligations must be tied to the role an issuer actually plays. 

When a PPSI directly issues or redeems stablecoins for a customer, it can collect information, screen wallets, use blockchain analytics, conduct due diligence, and maintain records. But once a stablecoin moves through exchanges, custodians, merchants, self-custodied wallets, decentralized protocols, or smart contracts, the issuer often does not know the sender or recipient, does not hold the customer’s assets, and does not control the transaction. 

That distinction matters when regulators require an issuer to freeze, seize, burn, or restrict stablecoins. In a custodial setting, that action may affect a specific account or wallet. In a decentralized liquidity pool or automated market maker, the same action could disrupt pricing, liquidity, collateral, or protocol operations for users with no connection to the enforcement target. 

TDC also urged FinCEN and OFAC to provide safe harbors or mitigating-factor treatment for PPSIs that act in good faith to comply with lawful orders while taking reasonable steps to limit harm to innocent users, liquidity providers, protocol participants, and other third parties. 

Taken together, these stablecoin compliance recommendations will create rules that are both strong and workable. 

What’s Next 

TDC will continue working with regulators and industry to ensure the final rule aligns realistic compliance obligations with customer relationships and asset control. Done right, the rule can support effective enforcement while giving responsible PPSIs the clarity they need to build in the United States. 

Prediction Market Monday: The History of Prediction Markets

Prediction markets in the United States can be traced back to the 1800s, when they were primarily focused on election outcomes. These hedging pools were organized on Wall Street directly outside of the New York Stock Exchange and posted alongside election news. They were seen as the most accurate forecasters.

1988

In 1988, at the University of Iowa, the Iowa Electronic Market (IEM) was launched as a research tool to study the ability of small financial bets to forecast election outcomes. In a 2008 study, IEM data was found to outperform national polls 74% of the time. The next prediction market to launch was InTrade in 2001. It became the most prominent market of its time, correctly predicting Obama’s 2008 victory. Its success was cut short when it was sued by the Commodity Futures Trading Commission (CFTC) for offering commodity options to U.S. customers without proper registration. This case warned other markets about the importance of regulatory compliance.

2010

In 2010, under the Dodd-Frank Act, Congress extended the CFTC’s exclusive jurisdiction over “agreements…and transactions involving swaps.” In 2014, PredictIt filled the gap left by InTrade. Its contracts focused on U.S. politics and operated under the guidance of a no-action letter from the CFTC. This letter allowed it to function, similar to the IEM, as a research tool using real-money trading. Despite the limitations of the no-action letter, PredictIt began to grow. During this period of growth for prediction markets, Augur launched the first blockchain-based prediction market. While there were initial challenges due to low liquidity, it laid out the groundwork for integrating blockchain technology with prediction markets.

2020

In 2020, the CFTC adopted a new regulatory approach to prediction markets, shifting from a primarily research-based framework to full approval under the designation of a contract market (DCM). Kalshi became the first prediction market to receive this approval. As part of this shift away from the research-based model, the CFTC withdrew PredictIt’s no-action letter.

This “open-arms” policy shifted in 2023, when the CFTC sought to restrict Kalshi from offering event contracts based on election outcomes. Kalshi challenged this decision in court and won. With a change in administration in 2025 that was more favorable toward prediction markets, the number of markets increased, and total market volume exceeded $50 billion by the end of the year. While at the federal level, governments were paving the way for prediction markets, the states in 2025 began to send cease-and-desists and sue CFTC-registered companies like Kalshi, claiming the contracts they offered trading on constituted “gambling” under state gaming laws. This began an over-year-long battle in the courts, that is still occurring, over whether event contracts are swaps, thus under exclusive federal jurisdiction, or gambling, allowing for states to have jurisdiction. In an amicus response on February 17, 2026, in the U.S. Circuit of Appeals for the Ninth Circuit, CFTC Chairman Mike Selig came out as saying prediction markets are swaps and thus fall under the exclusive jurisdiction of the CFTC. It remains unclear which way the courts will ultimately rule, and the issue may need to be resolved by the Supreme Court.

If you have any questions, please reach out to policy@digitalchamber.org. 

TDC CEO Testifies at Senate Banking Hearing Entitled: The Affordability Agenda

Cody Carbone
Chief Executive Officer, The Digital Chamber
U.S. Senate Committee on Banking, Housing, and Urban Affairs
Hearing Entitled: “The Affordability Agenda”
Tuesday, June 23, 2026


Chairman Scott, Ranking Member Warren, and members of the Committee, thank you for the opportunity to testify today.

My name is Cody Carbone, and I serve as Chief Executive Officer of The Digital Chamber, the world’s largest digital asset and blockchain trade association. Founded in 2014, our members include more than 250 companies globally across the digital asset and blockchain ecosystem, including exchanges, custodians, infrastructure providers, banks, developers, investors, and emerging technology companies working to build a safer, more competitive, and more inclusive financial system.

I am here today to offer solutions to the challenge of affordability weighing on Americans. The cost of accessing, moving, saving, and investing money should not be a barrier to any of these basic economic activities. The goal of the digital asset industry is to make it as easy to send money as it is to send an email.

For too long, American consumers and small businesses have been forced to operate on financial rails that are slow, expensive, and often difficult to access. These costs rarely appear as a single line item on a receipt, but they show up everywhere: in the price of groceries, in fees charged to small businesses, in the cost of sending money to family abroad, in the delay between earning a paycheck and being able to use it, and in the thousands of dollars families
must pay to close on a home.

That is the hidden affordability problem digital assets can help solve.

Digital assets and blockchain technology will not, on their own, slow inflation, increase the housing supply or wages, or fix every cost pressure facing Americans. But they can reduce the impact of friction and fees and offer competitive alternatives across the global financial system.

This matters most for households with the least room for error. The Federal Reserve reported in May 2026 that only 63 percent of adults could cover a hypothetical $400 emergency expense using cash, savings, or the equivalent – meaning more than one-third could not do so without borrowing, selling something, or being unable to cover the expense at all. 1The same survey found that 59 percent of adults had at least one major unexpected expense in the prior 12 months, with major vehicle repairs, home or appliance repairs, and major medical expenses among the most common.2

The FDIC’s most recent national household survey found that 4.2 percent of U.S. households – approximately 5.6 million households – were unbanked in 2023, while another 14.2 percent – approximately 19 million households – were underbanked.3 These are the Americans most likely to rely on costly, high-interest stopgap measures such as check cashing, money orders, payday loans, pawn shops, and other nonbank financial services.

Even for banked consumers, delays and fees are real and costly. Consumers paid more than $5.8 billion in overdraft and nonsufficient-fund fees in 2023, even after many institutions reduced those charges from pre-pandemic levels.4 And under Regulation CC, funds from many local checks generally do not have to be made fully available until the second business day after deposit, with only the first $275 generally required to be available by the first business day.5 For a household living paycheck to paycheck, that delay is not an inconvenience. It is a cost.

Digital assets can help lower costs in three areas to directly address the challenge of affordability: cross-border payments, everyday merchant payments, and the transfer and ownership of assets.

First, digital assets can reduce the cost of cross-border money transfers.

The United States is the largest source of remittances in the world. The International Organization for Migration has reported that the United States has consistently been the top remittance-sending country, and World Bank bilateral estimates have placed U.S. outward remittance flows at approximately $200 billion in a recent year.

6Globally, remittances to lowand middle-income countries were estimated to reach $685 billion in 2024 and were forecast by
the World Bank to reach approximately $690 billion in 2025.7

The World Bank’s Remittance Prices Worldwide database reported that the global average cost of sending remittances was 6.36 percent in its latest available report, more than double the international target of 3 percent.8 At that price, a worker sending $200 home may lose more than $12 to fees before the money even reaches the intended recipient. Across hundreds of billions of dollars in global remittances, those fees represent a significant economic loss for working families.

The problem is that cross-border payments often depend on multiple parties, different systems, different time zones, currency conversion, compliance checks, and settlement processes that were not designed for the modern digital economy. GENIUS Act regulated US dollar-backed stablecoins can help reduce that friction.

A payment stablecoin can move value globally, around the clock, over blockchain-based infrastructure. While on-ramps, off-ramps, foreign exchange, compliance, custody, and wallet services may still involve costs, the underlying payment rail tends to be faster, more
transparent, and more efficient than many legacy cross-border systems.

The same problem affects American freelancers, contractors, and small businesses. For example, a designer in South Carolina working for a client in Europe, a software developer in Arizona paid by a company in Asia, or a manufacturer in Ohio paying an overseas supplier all face the same basic problem: global payments are slow and expensive, creating a burden on those working to innovate and grow much-needed jobs in their communities.

That is why business-to-business payments have become a fast-growing real-world use case for stablecoins. McKinsey estimated in February 2026 that B2B stablecoin payments accounted for roughly $226 billion, or about 60 percent of global stablecoin payment volume, and that B2B stablecoin payments had increased 733 percent year over year.9 Artemis, Castle Island Ventures, and Dragonfly similarly found significant growth in stablecoin payment activity, including B2B use cases such as treasury operations and cross-border settlement.10

Businesses are using these tools because the payment rails are secure and fast. Lower-cost cross-border payments make American workers and American businesses more competitive, and all American consumers deserve access to these innovations.


Second, digital assets can put competitive pressure on the cost of everyday payments.


Federal Reserve data show how central card payments have become to everyday commerce. In 2024, credit cards accounted for 35 percent of consumer payments by number, and debit cards accounted for another 30 percent. Cash accounted for 14 percent.11

The cost of accepting card payments is material. In a 2025 report, the Government Accountability Office found that selected federal entities collected approximately $43.6 billion from consumers using credit, debit, and other payment cards in fiscal year 2023 and paid approximately $784 million in related fees. Those fees equaled 1.8 percent of revenue, and interchange fees accounted for nearly 90 percent of the fees paid by those entities.12

Federal Reserve data also show that payment network fees are significant. In 2023, network fees to all parties in debit card transactions increased to $12.95 billion, and acquirers and merchants paid 64.9 percent of those network fees.13

For large businesses, payment acceptance costs are a major operating expense. For small businesses operating on thin margins, they can be especially difficult to absorb. And because payment costs are part of doing business, they can affect prices, margins, wages, investment, and consumer choice.

Blockchain-based payment rails can introduce another option.

A regulated dollar-backed stablecoin can settle faster and often at lower cost than many traditional payment methods. Stripe, for example, lists stablecoin payment acceptance at 1.5 percent of the transaction amount in U.S. dollars, including conversion to fiat, wallet and AML screening, fraud prevention, and gas sponsorship.14 Stripe has also stated that stablecoin transfers typically incur flat network fees, often measured in pennies, and that for certain
businesses, stablecoin payments can cost about half as much as other payment methods.15

Properly regulated dollar-backed stablecoins can allow certain payments to settle faster, with greater transparency, and with a different cost structure than legacy payment systems. They should not replace cards, cash, ACH, wire transfers, or other payment methods. Different payment methods serve different needs, and consumers should be empowered with the best choices possible for their individual needs and preferences.

A cheaper, faster, compliant payment rail can give merchants more choices. It can allow businesses to experiment with lower-cost payment options. It can create pressure for incumbent payment systems to improve. And over time, greater competition in payments can benefit consumers.

It is also consistent with the way American markets work best. When a new rail can move the same dollar more efficiently, the answer should not be to block it. The answer should be to regulate it properly, supervise it effectively, and allow responsible market participants to compete.

That competition matters for small businesses. A family-owned restaurant, a local grocery store, a contractor, a barber shop, or an online seller may not have the bargaining power of a national retailer. Safer, more compliant, lower-cost options position businesses better to compete, invest, hire, and serve their customers.

Consumers benefit when payment systems compete, especially when innovation happens under U.S. rules, rather than in offshore markets where American regulators have less visibility to protect consumers.

Because of this Committee’s leadership, Congress has already taken a major step. The GENIUS Act created a federal framework for payment stablecoins, including requirements for reserve backing, public reserve disclosures, supervision, and compliance. That framework can help give consumers, businesses, banks, and regulators greater confidence that payment stablecoins are backed, redeemable, supervised, and compliant.16

Third, digital assets can reduce barriers to owning and transferring assets.

Tokenization is the process of representing ownership, rights, or claims on a blockchain. That can include financial assets, such as funds, bonds, Treasuries, private credit, collateral, and commodities. But it can also include real estate interests, invoices, receivables, warehouse receipts, supply chain records, intellectual property royalties, energy credits, and other records of ownership or entitlement.

That matters because today, too many markets still rely on fragmented, paper records and duplicative processes. One system records ownership. Another verifies documents. Another sends payment instructions. Another clears the transaction. Another settles it. Another reconciles the records after the fact.


Tokenization can help reduce that friction by allowing ownership records, transfer instructions, payment, settlement, and verification to operate through a shared digital infrastructure. That can mean clearer records, faster settlement, stronger auditability, fewer duplicative checks, and lower administrative costs.

This matters across the economy.

For funds and securities, tokenization can make issuance, subscriptions, redemptions, transfer agency functions, and investor recordkeeping more efficient.

For Treasuries and collateral, it can help assets move more efficiently through the financial rules and regulations that support the markets Americans rely on every day.

For small businesses, tokenized invoices and receivables can help verify payment rights, improve recordkeeping, and unlock working capital faster.

For supply chains, tokenized warehouse receipts and inventory records improve transparency and accuracy about who owns what, where it is, and when it changed hands.

And for real estate, tokenization can help modernize one of the most expensive and paperheavy transactions most Americans will ever experience.

When a family buys a home, thousands of dollars can be consumed by the process of transferring ownership, verifying title, moving funds, recording documents, and closing the transaction. Closing costs often range from 2 to 5 percent of the purchase price, not including the down payment.17

On a $350,000 home, which is currently lower than the median U.S. average price, that can mean $7,000 to $17,500 before a family receives the keys.

While those costs pay for important protections, it should concern everyone on this Committee that the largest financial transaction most Americans will ever make still depends on a process that can be fragmented, paper-heavy, duplicative, and expensive.

Homeownership is already hard enough, especially for first-time buyers. Fannie Mae has found that closing costs are a meaningful obstacle for first-time and low-income homebuyers. In an analysis of approximately 1.1 million home purchase loans acquired in 2020, Fannie Mae found that more than 14 percent of low-income first-time homebuyers had closing costs equal to or exceeding their down payment.18

Modernizing record-keeping, including proof of ownership, transferring value, and settling transactions, are a few ways to make life easier for our neighbors through transparency, reducing duplicative verification, improving auditability, and expanding efficient pathways for transferring interests in assets, rights, and records.

Beyond lowering costs, tokenization can be a key to unlocking access to ownership by reducing the cost of entry for large-scale investments.

Fractional ownership, when properly regulated, can allow participation in smaller increments while preserving investor protections, disclosures, custody standards, suitability requirements, transfer restrictions, and market integrity rules.

That expands wealth-building opportunities beyond those with existing wealth. Though not yet operating at a national scale, the potential is easy to see in the efforts made so far to tokenize and offer small shares for investors to buy and hold.
Major financial institutions, asset managers, technology companies, and market participants are already building toward a more efficient model for issuing, owning, transferring, and administering assets, rights, and records. Citi Institute projected in June 2026 that the global tokenized asset market could grow from approximately $17 billion today to $5.5 trillion by 2030.19 McKinsey has estimated that tokenized market capitalization could reach approximately $2 trillion by 2030, excluding cryptocurrencies and stablecoins.20

Those projections are not a guarantee. They show where markets are moving. A critical question that only Congress can answer is whether that activity will happen under U.S. rules, with U.S. regulators serving U.S. consumers and businesses, or whether it will move offshore.

Regulators are now implementing the GENIUS Act through rules governing issuer supervision, reserve standards, custodial and safekeeping requirements, Bank Secrecy Act obligations, sanctions compliance, and customer identification requirements.21

The GENIUS Act was a major bipartisan accomplishment. It showed that Congress can create clear rules for digital assets that support innovation, protect consumers, and give regulators the tools they need.

And we recognize the heavy lifting this committee has continued to do to ensure consumers, innovators, and regulators can build onshore with confidence.

On May 14, 2026, this Committee advanced the Digital Asset Market Clarity Act by a bipartisan vote of 15 to 9.22 That vote matters because market structure is the foundation for responsible digital asset innovation, and because digital asset regulation should not be partisan.

A clear market structure framework will define who the primary regulator is for what kind of token, what disclosures are required, how intermediaries must operate, how customer assets are protected, and how illicit activity is policed.

This matters for affordability because uncertainty carries a real cost. Muddy, antiquated regulations push responsible companies to divert resources from product development to legal and compliance, and cause banks and regulated financial institutions to hesitate to engage in emerging and more efficient products. Consumers are left with fewer regulated options, and regulators are forced to oversee a market without clear statutory tools.

The better approach is clear, durable law: a framework that defines regulatory authority, and gives innovators commonsense rules and obligations to ensure consumers can confidently participate in the market and have long-term protections.

Digital assets are not a silver bullet for affordability, but they are a practical tool for reducing financial friction.

Digital assets can help lower those costs, but only if Congress provides the clarity needed to build responsibly.

The Digital Chamber and our members are committed to supporting fair, responsible regulation. We support strong consumer protections with clear rules for market participants and innovators. Such a framework encourages and supports innovation in the United States.

If you have any questions, please reach out to press@digitalchamber.org.

TDC Applauds the Committee on Ways and Means for the Balanced Compromise Reflected in H.R. 9175

June 21, 2026

The Honorable Jason Smith  Chairman, Committee on Ways and Means  U.S. House of Representatives  Washington, DC 20515 The Honorable Richard Neal  Ranking Member, Committee on Ways and Means  U.S. House of Representatives  Washington, DC 20515 

RE: Support for H.R. 9175, the Tax Clarity for Mining and Staking Act, as Introduced 

Dear Chairman Smith and Ranking Member Neal: 

We, the undersigned organizations, write to applaud the Committee on Ways and Means for the balanced compromise reflected in H.R. 9175, the Tax Clarity for Mining and Staking Act, introduced by Representative Mike Carey, and to respectfully urge its passage as introduced. After years of uncertainty about how mining and staking rewards are taxed, the bill provides a durable compromise that innovators can support while addressing concerns raised by some lawmakers. 

Crypto and blockchain networks have the potential to integrate with and replace legacy systems across nearly every industry, delivering drastic improvements in speed, cost, and efficiency. However, these networks function only because participants choose to play a key role in validating transactions. Proof-of-stake and proof-of-work are the primary validation mechanisms in use today, with over $1.7 trillion in assets secured through these methods.1 It is critical that Congress provide legislative clarity in the tax code to ensure that those networks can be secured by Americans in America. 

Since Bitcoin’s inception in 2009, stakers and miners have lacked clarity in the tax code regarding the timing, sourcing, and character of the tokens they create through network validation. Recent developments make Congressional action even more urgent. In 2014, the IRS issued Notice 2014-21 stating that miners are required to include the fair market value of mined Bitcoin in gross income as of the date it was mined.2 In 2023, the IRS published Revenue Ruling 2023-14, setting forth the IRS’s position that validation rewards are stakers’ immediately taxable income.3 

3 Internal Revenue Service, Revenue Ruling 2023-14, 2023-33 Internal Revenue Bulletin 407 (August 14, 2023), https://www.irs.gov/pub/irs-drop/rr-23-14.pdf 2 Internal Revenue Service, Notice 2014-21, 2014-16 I.R.B. 938 (March 25, 2014), https://www.irs.gov/pub/irs-drop/n-14-21.pdf 1 See CoinGecko, Top Proof of Stake (PoS) Coins by Market Cap, https://www.coingecko.com/en/categories/proof-of-stake-pos (last visited June 18, 2026); and CoinGecko, Top Proof of Work (PoW) Coins by Market Cap, https://www.coingecko.com/en/categories/proof-of-work-pow (last visited June 18, 2026). 1 

Members of Congress have repeatedly flagged the problems this guidance creates. In November 2025, Senator Todd Young wrote to Treasury Secretary and Acting IRS Commissioner Scott Bessent, urging the IRS to reevaluate the ruling’s treatment of staking rewards, and the following month, Representative Carey led eighteen of his colleagues in a second letter pressing for updated guidance before the 2026 tax year began.4 Taxation at the time of creation results in myriad issues, including issues of dominion and control, taxation of phantom income, and liquidity concerns. Moreover, the guidance offers little analysis and conspicuously avoids key factual and legal considerations, casting doubt on its application to stakers and miners. Far from resolving the issue, this IRS guidance has further contributed to ongoing uncertainty, making prompt action by Congress all the more important. 

H.R. 9175 crafts a novel approach to the new technological and economic realities posed by proof-of-stake and proof-of-work blockchains, inspired by the century-old treatment of newly created property. The language reflects a hard-won compromise, with meaningful concessions on both character and timing to secure broad, bipartisan support. It does not provide unlimited deferral or full parity with all forms of self-created property; instead, it ensures income is recognized while avoiding immediate taxation before taxpayers can monetize the asset. That balance answers the central concern that the bill could create an unwarranted windfall. It also delivers something that years of administrative guidance have failed to provide: a clear, administrable rule that taxpayers can follow without ambiguity, and the IRS can enforce without having to chase recognition events across millions of wallets every time blocks are created on multiple chains. 

This is the needle H.R. 9175 threads to make sound policy. It ensures income is ultimately recognized while sparing taxpayers a tax on gains they may not yet be able to monetize. When a taxpayer owes tax on assets they cannot yet monetize, the practical result is forced selling: liquidating holdings simply to fund the tax bill, not because the taxpayer chose to exit the position. Moreover, H.R. 9175 ensures that taxpayers pay an amount in line with the income they realize at sale, unlike alternative proposals that could leave a taxpayer with a tax bill far higher than the amount they actually realize. 

The administrative costs of this approach are equally unjustifiable for taxpayers and the IRS alike. The Joint Committee on Taxation has scored the proposed amendment’s five-year cap and found that it yields negligible revenue while imposing a significant compliance burden on taxpayers, their advisors, and the IRS.5 For taxpayers and their advisors, it means tracking cost basis and computing gain on a mandatory five-year cycle across potentially millions of wallets, regardless of whether a sale has occurred. For the IRS, it means designing, staffing, and enforcing an entirely new class of recognition events—triggered not by a transaction but by the passage of time—across an asset class that already strains existing audit and reporting infrastructure. Piling that burden onto a provision that raises little meaningful revenue is poor tax policy by any measure. H.R. 9175, as introduced, achieves the same revenue goal—full recognition at sale or death—at a fraction of the administrative cost. 

5 Joint Committee on Taxation, Digital Asset Taxation (JCX-18-26) (June 8, 2026), https://waysandmeans.house.gov/wp-content/uploads/2026/06/JCT-Description.pdf 4 Letter from Sen. Todd Young to Scott Bessent, Sec’y of the Treasury & Acting Comm’r, Internal Revenue Serv. (Nov. 18, 2025), https://assets.bwbx.io/documents/users/iqjWHBFdfxIU/rrJFjBE.kMNI/v0; Letter from Mike Carey et al. to Scott Bessent, Acting Comm’r, Internal Revenue Serv. (Dec. 18, 2025), https://carey.house.gov/wp-content/uploads/2025/12/Rep.-Carey-IRS-Crypto-Tax-Staking-Letter.pdf 2 

We urge the Committee to preserve the balance reflected in H.R. 9175 and pass the bill as introduced. Reopening the compromise already struck in this legislation would risk reviving the very problems the bill resolves and stalling a bipartisan result that is finally within reach. Getting this right keeps blockchain validation and the innovation it supports built here in the United States. We are grateful for the Committee’s leadership and the hard work of staffand Members, and we stand ready to be a resource as the bill advances. 

Respectfully, 

For any inquires, please contact TDC at press@digitalchamber.org.