Chamber of Digital Commerce Submits Open Letter to President’s Working Group on Stablecoins

October 19, 2021

Stablecoins Do Not Pose Systemic Risk to the Financial System and are Not Securities

In recent weeks the President’s Working Group on Financial Markets has been developing regulatory recommendations for stablecoin payments systems. In an effort to contribute to the policy dialogue, the Chamber of Digital Commerce, the world’s leading blockchain and digital asset trade association, today submitted to members of the President’s Working Group a letter detailing our recommendations for the regulatory treatment of stablecoins. The letter was also sent to all members of the Financial Stability Oversight Council.

“Stablecoins are already fulfilling their promise of transforming today’s payments systems by enabling efficient, low-cost payments and increasing access to the financial system,” said Chamber of Digital Commerce founder and president Perianne Boring. “As the President’s Working Group considers a regulatory framework for digital assets – and specifically stablecoins – a balanced policy approach that encourages innovation and maintains U.S. global leadership in the digital asset and blockchain ecosystem is crucial.”

The Chamber believes the current federal and state regulatory regimes should remain in place. This will allow U.S.-headquartered, U.S. dollar-pegged stablecoin payments systems to be regulated in the same way that other U.S. digital payments platforms are regulated. These stablecoin payments systems, like other retail-focused payments systems, do not currently pose a systemic risk to the U.S. financial system.

The Chamber, however, also sees opportunities to enhance the U.S. regulatory approach for stablecoins via a policy framework that is principles-based and flexible, which would allow for new and innovative payments system structures to grow, while appropriately addressing potential risks. Such policies include: 

        • Streamlining state-level regulatory approaches in a way that follows the lead of states that allow certain stablecoin payments systems to obtain state-level special purpose charters.
        • Ensuring federal agencies provide clarity that most stablecoins are retail-focused digital payments instruments, not investment products. 
        • Simplifying tax treatment for stablecoin transactions. 
        • And, at the federal level, creating an optional special-purpose charter for stablecoin payments systems that meet certain regulatory requirements. 

    • “It is important for policymakers and consumers alike to understand that stablecoin payments systems offer opportunities for increased access to lower cost payments and financial services for everyone, but especially those who are currently underserved”, said Chamber chief policy officer Teana Baker-Taylor. “A policy framework that sets clear rules of the road, and is flexible enough to encourage ongoing payments innovation, is imperative to ensure the certainly needed by the digital asset industry to continue to build more efficient and effective payments systems.

      To achieve these important goals, the Chamber urges policymakers to put in place an appropriate policy framework for stablecoins to attain their full potential. This policy framework is not just important to the digital asset and blockchain industry. It is important for the U.S. to maintain its leadership position in the global innovation economy. The Chamber hopes its comments help achieve these worthy goals.