The Case for Principles-Based Stablecoin Regulation

Before I joined Anchorage Digital, I spent nearly a decade as a National Bank Examiner at the Office of the Comptroller of the Currency (OCC). My job was to walk into banks and ask hard questions. Is your liquidity real? Can you meet obligations under stress? What happens to your customers if something goes wrong? What do you need to operate safely?

Those questions don’t change because the asset is digital. And when I read the OCC's proposed rules to implement the GENIUS Act, I recognized exactly that instinct behind them. The OCC is doing what good regulators do: asking the right questions publicly, inviting industry to stress-test and validate its assumptions, and building a framework designed to protect holders before a crisis forces the issue. And the OCC must determine the best avenue to address the risks they see: What should be enshrined in the rule? what should be left to an individualized approach? What is certain today about the way stablecoins operate? And where do we need to leave room in the final rule for innovation?

Anchorage Digital Bank, National Association, has operated under the OCC’s direct supervision for over five years, longer than any other crypto-native firm. We became the first federally chartered stablecoin issuer in 2025. We have lived through every version of this question, in real time, with real assets, under real regulatory scrutiny, and we filed a formal comment on the proposed rules last week because we believe that experience is genuinely useful to the rulemaking process.

Our perspective is grounded in operating experience rather than theory, and our recommendations are aimed at strengthening what is already a serious foundation. This post is a plain-English version of what we said, and why we think it matters.

‍The structure of reserves matters as much as their quantity. 

Anchorage Digital holds reserves for each of our stablecoins in a separate legal trust. The reserves are legally distinct from our own assets. If Anchorage Digital were to fail, those reserves would not enter our receivership estate. Instead, fiduciary assets transfer to a successor trustee, and redemptions continue. Holders do not wait in line with our creditors. The proposed rule is principally calibrated to a debtor-creditor model, but the Act expressly permits others. We believe the final rule should accommodate them.

‍A mandatory redemption gate will cause the run it is designed to stop.

The proposed seven-day pause, triggered when redemptions exceed 10 percent of supply in a 24-hour window, is the most consequential miscalibration in the rule. The SEC spent more than a decade learning this lesson with money market fund gates. A publicly known, automatic tripwire becomes a reason for sophisticated investors to redeem before the gate drops. This ultimately accelerates the very outflows the rule is meant to slow. The SEC eliminated the gate framework in 2023. Stablecoin holders, with real-time on-chain visibility into flows, would have stronger incentives to run, not weaker. A discretionary supervisory approach, closer to the FDIC’s, would better serve the goal.

‍Mandatory cash deposits introduce the exact risk the rule seeks to avoid. 

The proposed requirement that issuers hold 10 percent of reserves at FDIC-insured banks or the Federal Reserve is intended to ensure liquidity. Applied at scale, it would force issuers to hold billions in uninsured deposits. This is exactly the kind of exposure that produced USDC's depeg following the failure of Silicon Valley Bank. Tokenized money market funds backed by Treasury securities offer comparable or faster liquidity without concentrating credit risk at any single institution, and government money market funds have historically seen inflows during periods of stress. The rule should focus on the outcome (demonstrated liquidity capability) and allow issuers to source it through instruments that do not concentrate counterparty risk.

‍Rigid portfolio rules will produce unintended consequences. 

A uniform 20-day weighted-average maturity cap, calibrated without regard to any issuer’s actual client base, will push issuers toward higher-risk instruments to compensate for yield compression. Custodian concentration limits sound prudent but force operational complexity that the world’s most sophisticated asset managers deliberately avoid. The better path is a principles-based framework: set clear outcomes, whether it’s daily and weekly liquidity capability or one-to-one backing under stress, and let each issuer demonstrate how they meet them.

‍Why this matters beyond crypto.

Payment stablecoins, done right, are infrastructure. They are a way to make the dollar faster, cheaper, and more accessible globally. Getting the reserve and redemption framework right is about protecting the viability of dollar-denominated payment infrastructure for the next generation.

The OCC has a genuine opportunity here. The GENIUS Act provides a strong statutory foundation; the proposed rules reflect serious effort to translate that foundation into operational requirements. We have been a federally regulated stablecoin issuer longer than anyone, and we built our secure reserve management approach and our redemption infrastructure under OCC supervision. We are sharing what works, and what the data suggests will not, because we want this framework to succeed.

Getting these rules right is how the United States cements its position as the home of the world’s reserve currency in its next form. And that’s precisely the legacy I believe this OCC will be remembered for.

‍The full comment letter is available [here].