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ARTICLE · 11 JANUARY 2021

OCC Issues Interpretation On Independent Node Verification Networks And Stablecoins

Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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Hogan Lovells Cadwalader

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In an interpretive letter, the OCC clarified that banks may (i) serve as participants, or "nodes," in Independent Node Verification Networks and (ii) use related stablecoin transactions to conduct payment activities,

United StatesFinance and Banking

In an interpretive letter, the OCC clarified that banks may (i) serve as participants, or "nodes," in Independent Node Verification Networks ("INVNs") (e.g., distributed ledgers) and (ii) use related stablecoin transactions to conduct payment activities, as these new technologies are "merely a new means" of performing "repeatedly recognized" permissible banking functions (e.g., providing payments services and facilitating payments).

The OCC described an INVN as being comparable to established payment systems that use a centralized entity because, in function, the INVN transmits payment instructions and validates payments. With regard to stablecoin transactions, the OCC explained, stablecoins are electronic representations of fiat currency and function - like debit cards and checks - as a mechanism of payment.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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