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The American Bankers Association (ABA), ACA International,[1] American FinancialServices Association, America’s Credit Unions, Bank Policy Institute (BPI), Consumer Bankers Association, Defense Credit Union Council, Electronic Transactions Association, Financial Technology Association, Mortgage Bankers Association, and Payments Leadership Council (collectively, the Associations)[2] appreciate the opportunity to comment on the Federal Communications Commission’s proposal (Proposal) to strengthen the …
Most Stablecoins Fall Short of GENIUS Act Reserve Requirements A recent BPI analysis examines which stablecoins on the market would comply with U.S. legal requirements to back coins with highly liquid assets and finds that only two of 10 of the largest dollar stablecoins – representing 26 percent of tokens outstanding – would meet GENIUS …
Stablecoins are digital tokens designed to maintain a stable value relative to a reference currency, predominantly the U.S. dollar. The outstanding amount of these instruments grew significantly in recent years before leveling off at around $300 billion in 2026.[1] In July 2025, Congress passed the GENIUS Act to establish a legal framework for “payment stablecoins” …
Ladies and Gentlemen: The Bank Policy Institute[1] is writing to express concern about the direction of anti-money laundering/countering the financing of terrorism modernization, which has left material gaps in illicit-finance coverage in the digital asset ecosystem. Historically, banks have played a key role in identifying suspicious activity and helping law enforcement to fight crime; they …
BITS
BITS is the technology policy division of the Bank Policy Institute. BITS provides an executive level forum to discuss and promote current and emerging technology, foster innovation, reduce fraud and improve cybersecurity and risk management practices for the nation’s financial sector.
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RESEARCH
The research department conducts long- and short-term analysis on issues primarily related to bank regulation and supervision with the objective of encouraging welfare-enhancing regulatory change. Our economists conduct academic-level research intended for presentation at conferences and publication in peer-reviewed journals.
