Stablecoin Legislation Must Respect the Dual-Banking System

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To be sure, the dual-banking system itself at present is far from federalism perfected, and state and federal jurisdiction over banks does overlap in important ways; state-chartered banks that are members of the Federal Deposit Insurance Corporation and/or the Federal Reserve System, for example, face additional federal supervision. But such federal bank supervision makes even less sense for stablecoin issuers, which ultimately provide a payment tool (tokens designed to maintain a 1:1 peg with the U.S. dollar), not banking services.



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