The Briefing Memo

April 2025 - If you’re new here, welcome to The Briefing Memo, which features the latest insights and updates from The Venture Dept.

Last week, we had the pleasure of co-hosting an engaging fireside chat with Rodney E. Hood, Acting Comptroller of the Currency, alongside my friend and co-host Aaron Brogan of Brogan Law PLLC. For this second Crypto Colloquy that The Venture Dept. and Brogan Law have organized together, we gathered at PubKey, the Bitcoin bar in Lower Manhattan that’s become a home for the crypto community (and even hosted the U.S. President during his campaign).

Rodney and I first met when I was leading innovation for the New York State financial regulator, and he was Chairman of the NCUA. His passion for public service and innovation was evident then and continues to be evident now. We’re fortunate to have someone as dedicated and forward-thinking as Rodney shaping the future of banking.

We discussed the OCC’s recent Interpretive Letter 1183, which allows banks to engage in crypto activities without prior approval, a significant step for national banks and the digital asset sector more broadly. Rodney’s enthusiasm for de novo bank chartering was also clear, something we explored amidst reports that digital asset firms are lining up to considered for the OCC's coveted trust bank charter. On tokenization and stablecoins, he shared his vision for their role in transforming banking and expanding financial access, a cause he’s long championed.

Many thanks to Rodney for taking the time to meet with the digital asset community and sharing his thoughtful perspective.

Next month we are partnering with Jenner & Block to co-host Stable & Stirred, a cocktail reception on May 28th, the evening before Stablecon. We’d love to have you if you’ll be in NYC that day.

Policy Updates

• White House and Executive Agencies: The President signed the very first crypto bill into law, which rescinded the IRS’ DeFi Broker Rule. That rule required developers of non custodial software, such as wallets, to submit information about their users to the IRS. A new DOJ directive now requires federal prosecutors to get approval before pursuing novel crypto enforcement actions.

• US Congress: Congress advanced two major stablecoin bills: the STABLE Act passed the House Financial Services Committee, and the GENIUS Act cleared the Senate Banking Committee, setting both up for potential floor votes. Meanwhile, the House held a key hearing on crypto market structure, highlighting bipartisan interest in modernizing securities laws to better fit digital assets.

• US Regulators: The Commodity Futures Trading Commission (CFTC) withdrew two advisories, CFTC Staff Advisory No. 23-07 and No. 18-14, to streamline regulations for digital asset derivatives and virtual currency derivative listings. The Senate confirmed Paul Atkins as the new SEC Chairman and the SEC’s Division of Corporation Finance issued guidance on crypto asset offerings and stablecoins. The Federal Reserve Board withdrew guidance requiring banks to provide advance notification for crypto-asset and dollar token activities.

What we’re reading

• Citi: Digital Dollars: Banks and Public Sector Drive Blockchain Adoption — A new Citi GPS report argues that 2025 could be blockchain’s “ChatGPT moment,” with regulatory clarity and public sector demand driving adoption of stablecoins and digital asset infrastructure. The report projects the stablecoin market could reach up to $3.7 trillion by 2030 and identifies growing use of blockchain in government finance, identity, and aid programs as key signals of mainstream momentum.

• Multicoin: Section 6(b)(5) White Paper — Multicoin’s new white paper argues that the SEC’s “Winklevoss Standard” is an unlawful and inconsistently applied barrier to digital asset ETPs. It calls for replacing it with objective listing criteria that would enable more regulated crypto products to come to market.

• SEC: Statement on Stablecoins — The SEC’s Division of Corporation Finance issued guidance stating that certain fiat-backed stablecoins redeemable at par for U.S. dollars and backed by liquid reserves are not securities under federal law. This view applies only to “Covered Stablecoins” that meet specific conditions, including full backing, redeemability, and transparent disclosure—and excludes algorithmic or interest-bearing tokens. The staff emphasized that this is a narrow, facts-and-circumstances determination, not a broad policy shift.

• SEC: Offerings and Registrations of Securities in the Crypto Asset Markets — The SEC issued updated guidance for companies registering crypto asset securities, emphasizing the need for tailored disclosures specific to the crypto market. The statement outlines expectations for describing project development, token economics, technical features, and risks—such as governance, security, and volatility—alongside standard securities registration elements. This guidance signals the SEC’s continued expectation that crypto asset offerings comply with federal securities laws.

On the horizon

May: Matt is speaking at Stablecon on May 29 in NYC. You can find more information about the event here: https://www.stablecon.com/.