
As a final nod of appreciation to @SenThomTillis and @Sen_Alsobrooks on their efforts to find a compromise, I want to point out just how dishonest the bank trades are in their latest analysis of the yield issue, even in these waning hours. Their joint press release complaining about the new language [1] mentions research that "demonstrates that yield-earning stablecoins could reduce all consumer, small-business, and farm loans by one-fifth or more, making it essential for the prohibition to be clear and transparent." That "research" is a post in Open Banker by Andrew Nigrinis [2] which summarizes the paper he wrote on this issue [3]. The analysis in both is rather troubling, bordering on dishonest. In the post, Nigrinis stated that any yield related to stablecoins could "siphon trillions of dollars from deposits." The word siphon is a link to a Reuters story about a Standard Chartered analysis that stablecoins could "..suck $1 trillion from EM banks in next three years." [4] The emphasis is mine, because StanChart is talking about emerging market banks, not American community banks. It's right there in the headline! The article even mentions specific countries like Sri Lanka, Pakistan, and Kenya. Nigrinis' conflation of the two is deceptive. If anything, stablecoins competing with offshore bank deposits will increase domestic deposits, as I argued in my response to the OCC on proposed rules for GENIUS. [5] Next, Nigrinis references "The U.S. Treasury’s April 2025 report." But as we all know, there is no such report. Instead what he links to is the Treasury Advisory Committee "thought experiment" [6], which was a private sector document (partially written by bank execs) that lacked rigor. Lastly, he cites an influential paper on CBDCs by Whited et al (one that I also mentioned in my comment letter). His reference doesn't mention the fact that this paper is. talking about a central bank digital currency, a far more radical product than a stablecoin. He quotes their analysis that $1 going into a CBDC may result in a loss of 80 cents in bank deposits, but leaves out their belief bank lending would only fall by only a quarter as much. He also ignores the overall thrust of the paper, which is that banks can still adapt in such a (radical, unlikely) world if there is a loosening of regs and capital requirements, both of which are happening independent of CLARITY. Sometimes, all you need to know when deciding who should win a debate is how badly one side is willing to ruin its own credibility to get its way. The bank trade group arguments on this issue were always rather swampy. At this point you could smell the rot. [1] bpi.com/banking-trades… [2] openbanker.beehiiv.com/p/stablecoinsh… [3] papers.ssrn.com/sol3/papers.cf… [4] reuters.com/business/finan… [5] regulations.gov/comment/OCC-20… [6] home.treasury.gov/system/files/2…


















