Young Kim

Bank Reg / Fintech Deposits & Payments Lawyer

[Young Kim @ghil04]

@bank_reg Here we go again....

[Young Kim @ghil04]

@Jeremy_Kress @SeanVanatta Ah! Thanks for clarifying. Thought you were referring to 4(m) notices themselves. Fascinating times...

[Young Kim @ghil04]

@Jeremy_Kress @SeanVanatta 4(m)'s...have never happened?

[Young Kim @ghil04]

Yowza. The TD order is even worse than we all expected. Forced annual 7% reductions until they get their s--- together.

Fair to say this is the furthest regulators have gone in actually "breaking up the banks."

https://t.co/QJ7Xrf9ube

[Young Kim @ghil04]

@bank_reg We all knew this to be true already, but perhaps shutting down any Loper challenges in advance?

[Young Kim @ghil04]

@bank_reg Six months ago the FDIC and OCC said June 2024 on both B3EG and LTD, so will take this with a healthy dose of salt....

[Young Kim @ghil04]

@regulatorynerd Big fan of ur work btw. Would love to connect one of these days.

[Young Kim @ghil04]

@regulatorynerd Don't disagree with you, just think issue's over-stated. Telling consumers their money's safer direct with banks just reduces risk to intermediaries...level of system funding should stay neutral. Not like banks won't still have access to IntraFi and others if desperate for liq.

[Young Kim @ghil04]

@bank_reg And still no QIS results to speak of...😒

[Young Kim @ghil04]

@ByKyleCampbell This was from the exchange with Sen. Vance, right? Frankly can't see how they push through wholesale changes without a re-proposal....

In any event, welcome back and thank you for the play-by-play.

[Young Kim @ghil04]

@ByKyleCampbell Best of luck! Sure there'll be plenty waiting for you once you're back to the grind

[Young Kim @ghil04]

@KarenPetrou Thank you for these insights, Karen. Out of curiosity, where are you seeing that the market cap for stablecoins is > 1 Trillion?

[Young Kim @ghil04]

@bank_reg Definitely the latter. New standard above/beyond Basel and will trigger industry blowback...

My 2cs: there are more efficient ways to test op readiness for FDW draws, and even 5 days may be too long given how fast $$ moves today (and even faster as instant payments scales)

[Young Kim @ghil04]

@regulatorynerd Isn't he supposed to be on court in a few minutes??

[Young Kim @ghil04]

@RobAMorg That's the piece that most surprises me. The fact the Fed wants to be notified of any "intent" to engage in dollar token-activities in addition to "testing" (w/e that means) suggests they are ramping up their focus on any firm even considering a deposit token....

[Young Kim @ghil04]

@jackchong_jc (1) we would eventually see a re-bundling of services as fintechs matured and, relatedly, (2) some fintechs would integrate their supply chain by hopping the regulated bank perimeter entirely (see sofi, lendingclub)

[Young Kim @ghil04]

I'm baffled that people would even believe this. The US is far from a CBDC.

And if you're scared of a digitized version of the dollar...the balance in your bank account is precisely that 😪.

[Kyle Campbell @ByKyleCampbell]

A lot of wild misinformation spreading about FedNow. Not going to retweet any (nor should you) but what you need to know is it is neither a central bank digital currency #CBDC nor a ledger for one. It's basically a faster version of the systems that've been in place for decades.

[Young Kim @ghil04]

@rexsalisbury Last year's Blue Ridge order is a clear warning shot of how the regulators intend to police this space....

[Young Kim @ghil04]

@SheilaBair2013 @WSJopinion I found it hard to read past this line: "In our fractional reserve system, banks lend out nearly all deposits...."

Even ignoring that mistake, this is a bad take. Forcing banks to rely on sweep networks is equivalent to making the FDIC share its premiums with private actors...