CTF Written Submission

Stablecoins—Potential Conflicts Between the Commission Staff’s Interpretation

April 30, 2025
  • The memo highlights a potential conflict between the SEC's requirements for Covered Stablecoins and state financial authority requirements, particularly those of the NYDFS.
  • It suggests that the SEC staff contact state agencies to align on Reserve requirements for Covered Stablecoins to avoid violations of federal securities laws.
  • The memo recommends clarifying the SEC's Statement on Stablecoins to ensure issuers understand the need for potential registration under the Exchange Act, Investment Company Act, and Advisers Act.

Last Reviewed or Updated: May 1, 2025