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Martin Carrica - Mountain Protocol
@mcarrica
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@ericrap71725940 @CampbellJAustin @malekanoms The law draft proposes them debt instruments with senior claim on the issuer, which they issuers are required to secure with HWLAs and redeem at $1.
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@e_woodford @ZeroHashX Who do you think eats the fees for interop / redemption fees? Passed to the user, the frontend or a new interop standard is established and players are forced to enter?
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@antoniogm Once we have a way to ensure no debanking, I agree. Many industries still running mostly cash, and not because they don't want bank accounts
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@TheChicagoVC @colleenklein @cmsholdings @nic__carter The armor piercing rounds picture selection is quite odd
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Yield on chain for regulated stablecoins is here, just not evenly distributed - USDM
If you think of Coinbase like a bank, we now hold about $0.42T in assets for our customers, which would make us 21st largest bank in the US by total assets, and growing. If you think of us more like a brokerage, we'd be the 8th largest brokerage today by AUM. If you think of us like a payments company…TBH i'm not sure where we rank on that list. There are various ways to measure it, but there were about $30T in total stablecoin payments last year (not all of those were goods and services though). The point is, with crypto the line between these categories is blurring. There are many legacy reasons these are separate in the traditional financial system - and not all of them are good reasons. Why does the money you spend lose value instead of growing in value like an investment? Why does your checking account not earn yield like a savings account (or better yet, like short term treasuries)? Many people use Coinbase to invest, but also to spend, get a loan, etc. In the updated financial system, you will have a single primary financial account which serves all these functions. A greater % of global GDP will run on more efficient crypto rails over time. We'll have sound money, lower friction transactions, and greater economic freedom for all.
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@OpenEden_X Congrats! Bermuda is the top regulatory body for stablecoins and tokenized assets. Great to have you on island as well
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@samuelmandrew Nothing BAD, but the things to improve are pitfalls that are left for the regulatory bodies to determine and could be bad - listed at the bottom
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@HawleyMO @BernieSanders @realDonaldTrump This will have the obvious consequence of reducing lending. The first to go will be riskier clients (aka, the poor, SMB's, startups, etc)
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@CampbellJAustin @DOGE I think all spend except for items related to national security (for secrecy purposes) should be public. For folks asking "why blockchain", it is the public database with the most transparency and ease to analyze
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@jackchong_jc MICA (EU), BMA (Bermuda), MAS (Singapore), ADGM (UAE) and (soon) FED/OCC (US) regulatory bodies have established that stablecoins are permissionless unless breaking rules and regulations, aka blacklist.
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@EleanorTerrett @SenatorHagerty We issue a prudentially regulated stablecoin. Overall very good. Has some pitfalls we should avoid, particularly on the capital requirement side.
Just finished going over the proposed Hagerty stablecoin bill. Let me say this is really well drafted to ensure we actually get stablecoins in the US, as it internalized checks and balances, learning from the hostile regulatory environment faced during recent years. The good: - Allows banks and non-banks to issue stablecoins. This enables more competition. - Mirrors the 2-tier banking system. You can be regulated by federal or state regulators (until 10B in issuance). More competition is better and I'm all for lowering barriers of entry. - Provides clear outcomes for insolvency. This is good but could be better. - Reserves are held on pristine assets that we know work (Tbills, insured bank deposits, repos). No risk to users. Shout out to recognizing risk of uninsured deposits. - No banning yield-bearing stablecoins - let issuers compete on distribution and features, doesn't make sense to ban yield if it does not add risk to the stablecoin (paying yield to distributors vs holders does not make a stablecoin riskier) - Clarifications on non-security, non-commodity - needed. - Study on inter operability - large stablecoins that have moats enter friction on redemption (USDT/USDC have 10bps redemption fees). This is the equivalent of a 10bps fee to take money from BOFA to JPM. Noting this issue and ensuring there is work here is very important. - Ensuring communications from regulators are in writing to avoid an OCP 3.0 - Checks and balances to ensure issuers are issued licenses fairly: default approved if no reply in 120 days after complete submission ackowledge, detailed reasoning for declines (grounds of denial, explanation required), delayed applications need to answer to congress, ability to appeal via hearing, judicial review for officers impacted by final actions (there are many other good actions, but these were notable) Things that could be improved: - Bankruptcy remoteness is not done via orphan SPV. This means that insolvent stablecoin holders could face unclear timelines to recover funds in case of insolvency. - Capital requirements were left open. Regulators could use this to kill stablecoins by making them unprofitable, just like MICA in the EU requiring 2% equity. This is a key item. - Commingling rules are not clear. - HOST STATE LAW: This regulation might kill state paths, as home state laws could mirror the MTL model, where companies take 4 years to get 50 MTL licenses. If the federal regulators allow state laws to become too different (or too aggresive on minor details) requiring multiple registrations, issuers will just go thrtough the Federal path, removing the lower barrier to entry intended in the law. The real unlock for this bill is it gives regulatory certainty to institutions. Hope we can support this bill as and industry and make sure we address the pitfalls to make this an industry with trillions of dollars.
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@SenatorHagerty @SenatorTimScott @SenGillibrand @SenLummis @RepFrenchHill @FinancialCmte @SenatorHagerty - first of all, congratulations on the highly drafted bill. As a prudentially regulated stablecoin issuer myself, here are some thoughts
Just finished going over the proposed Hagerty stablecoin bill. Let me say this is really well drafted to ensure we actually get stablecoins in the US, as it internalized checks and balances, learning from the hostile regulatory environment faced during recent years. The good: - Allows banks and non-banks to issue stablecoins. This enables more competition. - Mirrors the 2-tier banking system. You can be regulated by federal or state regulators (until 10B in issuance). More competition is better and I'm all for lowering barriers of entry. - Provides clear outcomes for insolvency. This is good but could be better. - Reserves are held on pristine assets that we know work (Tbills, insured bank deposits, repos). No risk to users. Shout out to recognizing risk of uninsured deposits. - No banning yield-bearing stablecoins - let issuers compete on distribution and features, doesn't make sense to ban yield if it does not add risk to the stablecoin (paying yield to distributors vs holders does not make a stablecoin riskier) - Clarifications on non-security, non-commodity - needed. - Study on inter operability - large stablecoins that have moats enter friction on redemption (USDT/USDC have 10bps redemption fees). This is the equivalent of a 10bps fee to take money from BOFA to JPM. Noting this issue and ensuring there is work here is very important. - Ensuring communications from regulators are in writing to avoid an OCP 3.0 - Checks and balances to ensure issuers are issued licenses fairly: default approved if no reply in 120 days after complete submission ackowledge, detailed reasoning for declines (grounds of denial, explanation required), delayed applications need to answer to congress, ability to appeal via hearing, judicial review for officers impacted by final actions (there are many other good actions, but these were notable) Things that could be improved: - Bankruptcy remoteness is not done via orphan SPV. This means that insolvent stablecoin holders could face unclear timelines to recover funds in case of insolvency. - Capital requirements were left open. Regulators could use this to kill stablecoins by making them unprofitable, just like MICA in the EU requiring 2% equity. This is a key item. - Commingling rules are not clear. - HOST STATE LAW: This regulation might kill state paths, as home state laws could mirror the MTL model, where companies take 4 years to get 50 MTL licenses. If the federal regulators allow state laws to become too different (or too aggresive on minor details) requiring multiple registrations, issuers will just go thrtough the Federal path, removing the lower barrier to entry intended in the law. The real unlock for this bill is it gives regulatory certainty to institutions. Hope we can support this bill as and industry and make sure we address the pitfalls to make this an industry with trillions of dollars.
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