There is a lot at stake in the meaning of the word "interest," as initially interpreted by Treasury and then likely by the courts. Today, the Blockchain Association (supported undoubtedly by numerous others) argues for a narrow definition of the term. Note yesterday's article in which bankers argued for a broad definition. .

Here are the words of the statute: (11) PROHIBITION ON INTEREST.—No permitted payment stablecoin issuer or foreign payment stablecoin issuer shall pay the…

It is unfortunately the case that policies that make a show of protecting lower income consumers have the effect of making products unavailable to them. It is obvious that there is an administrative cost to making a loan, and that the administrative cost is not an entirely variable amount; there is a certain minimum cost for making any loan. If legislation makes it impossible for a bank to earn an amount equal to the sum of (i) the administrative cost of the loan, (ii) the cost of the money,…

The government puts itself in a difficult position when it goes into the business of mandating prices and business terms. Leaving aside the economic issues, there are complicated issues as to privacy and data security.  

Notable that an enforcement action was brought wholly on the basis of deficient procedures (which, in fairness, looked pretty deficient) without any finding of harm to customers.