What should be done in the US? Patrick Collison, the co-founder of Stripe, told the House Financial Services Committee that “Stripe strongly supports the concept of some sort of federal payments charter”. I do too, not that it matters. But what could such a Federal Payments Charter (FPC) look like? And what would it achieve.
Well, let me begin by stating clearly that Collison is absolutely right about this and I simply do not understand why his suggestion is not already US policy. I have long thought that some kind of OCC federal charter that would allow regulated institutions access to payment systems, but would not allow them to provide credit, is a straightforward way to improve American financial infrastruture and bring more competition into the world of payments. Such a charter would separate the systemically risky provision of credit from the less risky provision of payment services but creating a new kind of financial institution, rather like the European “Payment Institution” or Indian “Payment Bank” that does nothing more than hold customer money in accounts that can be used to send and receive payments.
I am far from the only person who thought this, by the way. Mihir Desai and Sumit Rajpal, wrote in the Harvard Business Review other countries have begun exploring ways forward and note in particular that the US can learn from what the United Kingdom, Australia, and Singapore have all been doing. They identity two broad solutions: Allow nonbanks to access the payment system as the UK and others have allowed, or create banks that do nothing more process payments. They focus on the latter, but I think we want Federal Payment Institutions (a regulatory category that I just made up) that do both. Such institutions could then issue stablecoins in a sound and well-regulated manner to the great benefit of consumers and businesses around the world.
J. Christopher Giancarlo, former chair of the U.S. Commodity Futures Trading Commission, Daniel Gorfine of Gattaca Horizons and Brian Peters from Stripe put forward an detailed (and excellent) exposition of the issues in a article on “The Case For Payments Modernization” in the Milken Institution Review. They point out that under both Republican and Democratic administrations, the US Treasury recommended the establishment of a federal payments framework and are clear than the kind of FPC envisaged would be limited to providing payments and related technology services, avoiding traditional banking activities such as lending. An obvious one of those “relatred technology services” is stablecoins.
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In his recent book, Beyond Banks, Dan Awrey similarly seeks to answer a basic question: “why the United States was able to send 24 men to the moon, but seems chronically incapable of delivering a cheap, fast, secure, and universally accessible system of money and payments.” His work explores a fundamental conflict embedded within the structure of our financial system:
This tension is a product of the fact that we rely on banks to perform three critical and, at least as presently constituted, intertwined functions. The first is the provision of loans and other types of financing to people, businesses and governments, thereby necessitating that banks hold risky and often illiquid longer-term assets. The second is money creation, with short-term and highly liquid bank deposits representing by far and away the largest source of money in the modern economy. The third is payments, where banks serve as both the gatekeepers and custodians of the vast and sprawling network of financial plumbing that moves money across time and space in satisfaction of our financial obligations. As economist Matthew Klein recently put it, this essentially makes banks “speculative investment funds grafted on top of critical infrastructure.”
From: The Case for Payments Modernization – Milken Institute Review.
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Today, it is not gold or silver content that determines the intrinsic value of money, but laws and institutions that underpin it. At the same time, payments utility is determined by technological advances that can outpace changes to these laws and institutions. As a result, bad money often gets bundled with good payments. People are offered cheaper, faster, more convenient, more secure, and more accessible ways to send and receive money at the expense of the underlying money being less sound. In times of relative stability, bad money may offer a comparative advantage.
Awrey calls this Gresham’s New Law and lays out a blueprint to address it.
From: Gresham’s New Law – by Marc Rubinstein – Net Interest.
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Now it is quite understandable that the incumbent banks are not happy about this. Generally speaking, the big banks earn about a third of their revenues from payments and every payment provides invaulable data that the institutions can use to learn more about their customers.