Stablecoins are a very hot topic, and not only among crypto enthusiasts. This is “Crypto Week” in Congress, but current activity in the stablecoin (SC) space ranges from an explosion of transactions and issuance by banks and other institutions, plans for issuance by other businesses like large retailers, the introduction of new embedded SC features, laws affirming the right of use in non-crypto transactions, regulatory maneuvers, and central bank scrutiny.

The Digital Money Realm

An SC is a digital asset convertible to currency at a value pegged to some other asset with a stable market value. SCs are almost all pegged to the dollar, but they can be algorythmically pegged to a basket of currencies, Treasury securities, gold, silver, or other commodities, or a combination of various kinds of assets. Still, it’s thought that the growth of SCs will reinforce the dollar’s position as the world’s dominant currency.

SCs had their genesis and are still primarily used for settlement of transaction involving crypto-currencies and cross-border transactions. They function as a store of value and provide investors exposure to the underlying asset(s), but they are increasingly seen as transactions media as well. They offer a direct channel to instant settlement without other intermediaries and with low transaction costs.

Unfortunately, the purported stability of SCs has not always held up. In 2022, the collapse of the SC Terra/Luna demonstrated that a run on an SC is a real risk. Pending legislation in the U.S. will attempt to address this risk (see below). Tether is the dominant SC on the market today, and its issuer, Tether Ltd., claims to back it with 100% fiat currency reserves. However, those claims have come under suspicion with concerns about the true liquidity of their backing. Tether has other problems, including money laundering allegations. The bills now under consideration in the Congress would require a major change in the way Tether and other SC issuers do business in the U.S.

Crypto-Week Pending Legislation

SC issuers hold levels of reserves against their outstanding value, but currently only under various state regulations. That’s likely to change soon. Bipartisan legislation is moving through Congress: the so-called GENIUS Act was approved by the Senate in June; the STABLE Act in the House has many similar provisions.

The GENIUS and STABLE bills would require public disclosure, frequent audits, and establish 100 percent reserve requirements for so-called “payment” SCs. The bills also stipulate that reserves must be held in highly liquid assets like U.S. dollars, money market fund shares, and Treasury securities maturing within 93 days. This is likely a disappointment to “hard money” partisans who’d like to see SCs backed by precious metals. Both bills would also prohibit interest-bearing SCs, obviously an impediment to risk-taking by issuers and also a nod to banks hoping to avoid new competitive pressures. Altogether, the bills would make SCs more currency-like and less vehicles for saving or speculation of any kind.

A third piece of federal legislation, the so-called CLARITY Act, would sort out the regulatory roles of different federal agencies pertaining to digital assets.

CBDC

Central banks like the Federal Reserve have taken a keen interest in SCs, which amount to an alternative monetary system. Advocates of a Central Bank Digital Currency (CBDC) maintain that it would have greater stability and public trust than privately-issued SCs. No doubt a CBDC would facilitate investigation of fraud and money laundering, and supporters say it would help preserve the sovereignty of the U.S. monetary system.

However, a CBDC is off the table in the U.S. for the foreseeable “political” future. President Trump has issued an executive order (EO) prohibiting the development or issuance of a CBDC in the U.S. The EO asserts that a CBDC would not promote stability and in fact would do the opposite.

Opposition to a CBDC revolves around several issues: 1) it would cause an atrophy in the private development of digital assets and SCs in the U.S.; 2) a CBDC would create grave concerns about surveillance and potential use of the CBDC as an input to a social credit tool; 3) the alleged risk of a CBDC to the stability of the banking system. #3 is apparently in reference to possible disintermediation when a CBDC is substituted for traditional bank deposits — but SCs have been noted for that same risk.

Neither the GENIUS Act nor the STABLE Act explicitly prohibits a CBDC, which has riled a few conservatives. However, there are provisions in the GENIUS Act that effectively rule a CBDC out at a “retail” and consumer level.

A fourth piece of legislation, the Anti-CBDC Surveillance State Act, would prohibit the Federal Reserve from “… testing, studying, developing, creating, or implementing a central bank digital currency and bar the banks from using such a currency to implement monetary policy.” The bill was passed by the House of Representatives in May, but it has yet to clear the Senate. Some House members might like to have its major provisions incorporated into the current SC legislation, but that remains to be seen, and if such a revision was passed by the House it would require another Senate vote in any case.

Not Quite Like Cash

As a “programmable” currency, a CBDC could be used to control transactions deemed impermissible by a future “regime”. This would be a manifestation of what Dave Friedman calls “The Convergence of AI and the State”. His concerns extend to privately-issued SC’s as well, inasfar as SCs and other payment systems have us “sleepwalking into a cashless society”.

Privacy has been a downside to SCs and all blockchain transactions from the start, but there are several technological extensions that could protect SC transactions and accounts from nosy governments or nefarious actors. Taurus, a crypto custodian, has launched a Stablecoin contract for businesses with privacy features using so-called zero knowledge proofs that would satisfy “Know Your Customer” requirements and anti-money laundering laws, but without revealing amounts paid or the recipient’s identity. Still, there are legitimate concerns regarding access by regulators, and law enforcement could ultimately gain access to account and transaction data given a reasonable suspicion of wrongdoing. This will almost certainly be addressed in any SC legislation that makes it to Trump’s desk.

Macro Policy Implications

Will broader adoption of SCs compromise the ability of central banks to conduct monetary policy? Scott Sumner says no:

“The Fed will still control the monetary base, and they have almost unlimited ability to adjust both the supply and the demand for base money.  This means they will be able to react to the creation of money substitutes as required to prevent any impact on macroeconomic objectives such as employment and the price level.”

When Sumner’s says the Fed controls the demand for base money, he refers to the interest rate the Fed pays on bank reserves.

As noted above, however, it’s widely feared that public substitution of SCs for bank deposits could drain bank reserves, adding variability to the broader demand for monetary assets, thus weakening the relationship between policy actions, the money stock, and other key variables.

Even if this is correct and Summer is wrong, the Federal Reserve should be treated as a special (but very important) case. That’s because the dollar is the dominant global currency, almost all SCs are backed by dollars, and essentially all SCs used in the U.S. will be backed by dollar-denominated assets should GENIUS-type legislation become law. That severely limits any potential disintermediation that SCs might otherwise cause. Control of bank reserves should be manageable, and therefore SCs will not meaningfully weaken the Fed’s control of base money or the transmission of monetary policy.

Things are not so simple for countries having home currencies that play a minor role internationally. SC’s backed by other currencies or assets are then more likely to weaken the central bank’s control of domestic monetary assets. In fact, SCs might create greater vulnerability to “dollarization” in some countries, which would weaken the efficacy of domestic monetary control. If Sumner is correct, the existence of SCs would still add a layer of variability for these central banks, making policy adjustments more complex and error-prone.

Conclusion

Stablecoins are already huge in the crypto world and they are making inroads to the broader financial sector, factor payments, and everyday consumer decisions. Naturally they have attracted a great deal of interest in policy circles, both for their benefits and the risks they present. The purported liquidity and stability of SCs, together with a few prior missteps, make the legislation now before Congress a key to broader adoption, particularly the provisions on reserves and transparency. While not strictly a part of the legislation, the incorporation of privacy features will enhance the value of SCs to all users.

Conservatives and libertarians undoubtedly will welcome the proscription on development of a digital currency by the Fed. Private SCs backed by dollar reserves should allow the Fed to maintain ample control over the monetary base and the supply of monetary assets. Moreover, the growth of dollar-backed SCs will strengthen the dollar’s dominance in international trade and finance. However, while stablecoins can and do reduce transaction costs in a variety of circumstances, dollar-backed SCs cannot be better stores of value than the dollar itself, which we know has had its shortcomings over the years.