Stablecoin Scenarios

Summary

The digital asset ecosystem has graduated from a decade of speculative experimentation to a decisive phase of infrastructure modernization. For fifteen years, the discourse surrounding blockchain technology has been dominated by the volatility of crypto-assets, effectively obscuring the underlying utility of the technology. That era has concluded. We are now witnessing the industrialization of the sector, where stablecoins have emerged not as a new form of money, but as a fundamental settlement innovation (see blog).

The GENIUS Act has provided the regulatory clarity required to transition stablecoins from the periphery of finance to its very core. This legislative milestone has catalyzed a geopolitical shockwave, prompting European finance ministers to declare U.S. stablecoins a greater threat to monetary sovereignty than trade tariffs. But while the Genius act codified “trust” in an instrument (reducing settlement risk to stablecoin issuer balance sheet), it does not address disputes and broader governance issues associated with managing participants across diverse processes and regulatory regimes.

The maturation of stablecoins is not a revolution that overthrows established banks and payments system; it is an evolution that upgrades it. The rails are being replaced while the train is moving, and those who understand the mechanics of the new tracks will determine the destination of global capital.

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The Neobank Revolution? Not how I see it… 

As most of you know I led channels for Citi back in the “direct banking” days. My team in the UK bought Egg (2007) and while I didn’t have oversight of the US I did have the 35 other Geographies. I also ran online and payment services for Wachovia (3rd largest online bank at the time). I’m here at FinTech NerdCon this week and have listened to Nubank co-founder and Chime. While I congratulate their growth and their Nubanks’ progress outside the US, count me as a skeptic of their profitability (and progress) in the US. 

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Genius Law – What to Expect?

Yesterday President Trump signed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act into law, clearing the path for dollar-backed stablecoins. As I’ve argued before, the future of money is a new model of trust, and this legislation provides the regulatory certainty needed for that trust. 

The GENIUS Act is a landmark piece of legislation. It establishes a dual charter system, enabling both federal and state-regulated stablecoin issuers. The key provisions are precisely what the industry needed: a mandate for 1:1 reserves with high-quality liquid assets like cash and short-term treasuries, a prohibition on reusing those reserves, and the designation of issuers as financial institutions under the Bank Secrecy Act. This isn’t just about compliance; it’s about building a foundation of trust that can be exported globally.

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APIs – More Banks to Follow JPM – Pricing Implications

As I stated in my Monday blog, Open Banking is dead in the US. Pay by Bank (and open banking) is effectively dead in the US. This follows JPMorgan’s move to push out its new API pricing structure to data aggregators and other third parties in the first week of July. This development comes as the “new” CFPB seeks to vacate its Section 1033 rule.

The latest is that we can expect most other major banks to roll out their own pricing within the next two weeks. These banks will have different pricing, as there was no coordination among banks. JPM has always been the most forward in protecting consumer data. A new pricing floor for data access has been established. Now that other analysts have weighed in, I can recap the pricing framework. 

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Open Baning is Dead in the US

Last week, I shared the news that JPMorgan has started charging for API access, a move that many see as a death blow to pay-by-bank and open banking in the US. While this might sound dramatic, I believe it’s a necessary reset. The truth is, the current model was never sustainable, and with the CFPB’s recent move to vacate its unlawful 1033 rule, the writing is on the wall. Open banking as we know it is dead in the US.

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Understanding Payments Data – How it Plays Today and the Near Term Future

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I thought it was time for a payment data update. Given Paypal’s Feb 2025 investor day, JPM’s “Retail Media Network” now re-labled Media Solutions and JPM’s lawsuit against Transunion/Argus. My perspective is formed from my 8 yrs as CEO/Founder of Commerce Signals. I’ll touch on signals, intent and agentic at the end. 

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Top US Banks to Issue their own Stablecoin

Executive Summary

  1. As a former Banker running payments for 2 of the largest US banks I have a perspective on how this will play out. I may be wrong, but it is an informed perspective.
  2. As outlined 2 weeks ago banks in the EU are planning their own stablecoins.
  3. The GENIUS ACT forces stablecoin issuers to obtain bank licenses, thus this morning’s WSJ report that Bank of America, Wells Fargo and Chase are now in the mix is only logical
  4. As outlined in Stablecoin predictions, this will not impact cards as they retain their role in the last mile and banks protect the card model. 
  5. As outlined in Power of Bank Networks, Payments are where the power of banking is unlocked. The major US banks are payment hubs that connect to all networks, from TCH, RTP, Swift, Card, …etc.  These banks are leaders in innovation and in managing operations that consistently clear trillions of dollars PER DAY. 
  6. The stablecoin settlement model is much simpler than an RTP network where each participating party has to register as a sender or receiver of payments. Senders must have settlement funds which restrict their ability to clear payments. In a Stablecoin model, originators only have to have valid stablecoins to transact, and can also create programmable rules around them (see Programmable Money)
  7. The business drivers are remittance, cross border, B2B, and the prospect of growing the global deposit base as international consumers and businesses buy stablecoins. Italy’s finance minister is quoted as saying USD stablecoin adoption (ie dollarization) represents a greater threat to the EU than Tarriffs. 
  8. In my view this is a 3 yr effort. Banks don’t move quickly in isolation, and even more slowly in consortium. I do think that this will first move with commercial use cases and remittances, with banks as stablecoin issuers. Within retail consumer UCs, P2P and Zelle are the area that would be impacted first.  
  9. US Banks should consider the slippery slope of Stablecoin. Once issued, their transfer can’t be restricted, and will operate without friction. Every movement of money becomes instant. This is why I don’t think we will see consumer interfaces within US bank domains in near term. Priority 1 is creating the stablecoin issuing platform and legal structure. Priority 2 is focusing on UCs like cross border and B2B. 

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