Arguably, Brian Brooks has done more than anyone to spur the epic bull run of the last few months. The former head of the Office of the Comptroller of the Currency (he served from May 2020 to mid-January 2021) paved the way for U.S. banks to adopt cryptocurrency, including allowing federally regulated banks to custody digital assets and even act as stablecoin nodes

Some saw these actions as pivotal for banks to embrace the shift to a decentralized, open-source economy. Brooks envisioned a future with “self-driving banks” in a Financial Times op-ed. However, there are good reasons to think banks will proceed with caution on adopting cryptocurrencies, and stablecoins in particular. 

Rafael Cosman is the CEO and co-founder of TrustToken, makers of the digital dollar TUSD and four other global fiat-backed stablecoins.

Firstly, the OCC memo contains several explicit provisions that put significant responsibilities on banks and stablecoin issuers. These include know-your-customer (KYC) requirements and the need for “appropriate systems, controls, and practices in place to manage […] risks, including to safeguard reserve assets,” among others. 

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