authorized the FDIC to act not only as the liquidator of banks, but also as the liquidator of other large institutions, such as broker-dealers, that might fail. Given that the FDIC has no experience overseeing these institutions, or with the types of transactions that they enter into, or how they manage their funding, or hold their assets, it seems to be extraordinarily wishful thinking on the part of Congress to believe that the FDIC could step in during a crisis and manage a large failing…

It is interesting that Governor Brainard describes Libra as a "stablecoin," as that uses the term rather broadly. Historically (if that is a word that can be used in connection with digital currencies), stablecoins were linked to a fixed amount of a single currency (although the term also could be applied to a digital currency linked to a fixed amount of multiple currencies or assets). Unlike these "traditional" stablecoins…

Matt Levine, of Bloomberg, offers excellent insight about this . For some broader context, consider this on the SEC staff's issuance of a no-action letter to "Pocketful of Quarters" ("POQ"). In the POQ case, a company produced a token intended to be used in video games. The facts set out in the POQ no-action letter are distinguishable from those at issue in the Grams case in that (i) according to the letter, the video game technology was already "built" and (ii) there were strict limits on…