I've posed a new essay on SSRN discussing what I call presidentially-connected firms and the importance of having independent regulators. I also guesstimate that President Trump is receiving about $13 million annually from his interest in the USD1 stablecoin.
Here's the link: How does this work? World Liberty Financial seems to have a licensing agreement with BitGo, which is a "stablecoin-as-a-service" provider. From my examinations of his disclosures, President Trump owns a 28% stake in WLF. 2/
If WLF and BitGo maintain a 50-50 split on net interest revenue, as has been the case in other stablecoin arrangements, the 4.3% Treasury bond interest rate and 2.2 billion USD1 in circulation results in Trump receiving ~$13 million. 3/
BitGo applied to the OCC for a trust charter, and may apply to the OCC for a stablecoin issuer license. Given that economic regulators are not independent of the White House, Trump could tell the Comptroller to approve BitGo's applications. (There's no evidence he has done so.) 4
The risks posed by presidential control of regulators with oversight of presidentially-connected firms are huge. The president could direct that the law not be enforced against his firms, or direct the law be overly-enforced against his competitors. 5/
Who's at risk? First, customers of the presidentially-connected firm. Customers have no private right of action under the GENIUS Act, and if the OCC doesn't effectively regulate the firm, no one can. 6/
Then, there are risks for competitors, who may have to compete on an unlevel playing field. 7/
Finally, there are risks to financial stability. If the presidentially-connected firm must quickly liquidate treasuries to meet redemption requests, it could disrupt the treasuries market. 8/
The conclusion, I think, is for Congress to implement legislation discouraging the removal of agency officials so that the OCC can remain independent of the president. It's still a work in progress, so comments are welcome! 9/9
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