2026 Financial Markets Conference – Policy Session 2 Transcript - May 18, 2026

May 18, 2026

Policy Session 2: Banking in a World with Stablecoins and Tokenized Assets

With the passage of the GENIUS Act, the United States has established the regulatory framework for stablecoins—a digital asset designed to keep its value one-for-one with the US dollar and which clears on a digital blockchain. In addition, tokenized money market funds where traditional money markets are tokenized and cleared on a blockchain are now being launched. In this session, the advantages of these bank and nonbank digital assets were debated in terms of modernizing the payment system, increasing the competition for financial services, and rethinking the bundling of traditional banking credit transformation and money creation with payments. In addition, how will the benefits from the increased competition of nonbank stablecoins be balanced against their impact on financial stability and their runnability?

Transcript

David Wessel: We're back. Thank you for joining us. We're going to continue the conversation about what the world looks like with stablecoins and tokenized deposits. I'm not going to speak much because we have three experts here, and they know a lot more than me; but I am struck by the fact that we're fixated on stablecoins, tokenized deposits, payments with our phones—and yet, the demand for currency in the Atlanta Fed district is so great that they have consolidated their cash vault in Miami and made it bigger. They have now the biggest cash vault in the Federal Reserve System, because the demand for currency (presumably from Latin America) is so strong.

But it'll only be the largest vault in the Federal Reserve System until the New York Fed expands its vault in northern New Jersey. So, we may be fixated with stablecoins, but there are a lot of people out there who still like cash.

So, we have a great panel here today to follow on Francesca's presentation with three very different perspectives. Dan Awrey is a professor at Cornell Law School and has written a book called Beyond Banks: Technology, Regulation, and the Future of Money, which seems particularly relevant.

Carolyn is in the banking system, so she may or may not be intermediated by what's happening, but her job, first at BlackRock and then at BNY (The Bank of New York Mellon Corporation), is to figure out what innovation means for them. And John Schindler is at the Financial Stability Board—the General Secretary—where he's been since February 2023. Previously, he spent 20 years in the Financial Stability Division at the Federal Reserve, and his job is to make sure that the other two don't screw up the system so we all get screwed.

So, each of them is going to speak from the podium; each of them has slides—about 10 minutes each—and then we'll have a conversation. You can use your app to ask the questions. I have plenty, but I'd much rather hear yours. So, please use the "Ask a Question" button on the app. And Dan, the floor is yours.

Dan Awrey: Thank you so much—to the organizers, to David, and the panelists. As the first presenter on this panel, I've been given the assignment of setting the scene, I think, at a high level of description, to understand what we mean when we talk about a world of stablecoins and tokenized assets. I'm going to focus on the payment system, and the ecosystem that is built up around the payment system, as a starting point.

Hopefully, something like this looks familiar to everyone. This is the basic structure of the existing bank-based payment system. A couple of important features of this system: one, we have one type of network node—banks, that are subject to relatively homogeneous regulation. Two, it is effectively a closed hub-and-spoke network, so we have participants in this system strictly policed—that is, we let banks into the system, but not other types of financial institutions.

And at the heart of this system is both the Federal Reserve, and other types of financial markets' infrastructure. And indeed, the Federal Reserve plays a number of important roles within this system. It is the owner and operator of several payment systems; it is the regulator of payment systems; and of course, it provides liquidity support to the payment system in general, and the various institutional nodes within it.

The emerging ecosystem for payments, such as it is, is built off this system but involves two important changes that I want to highlight. The first is that we are now moving beyond banks to other types of network nodes. I've given a couple of examples here; one that we might think of as a pretty conventional non-bank node at this point is PayPal. Another, we've talked about already today, the stablecoin issuer, Circle.

But there's lots of other types of nodes, new nodes within this network. We can think of firms like Stripe, Ramp, or Shopify, all of which, in some form or another, want to connect to the existing financial system—the payment system. But at the moment, in terms of transferring value, [we] have to do so through banks.

This first change has then led to a second change, which is depicted in this graph, which is that the network structure itself is starting to change. So now, we have nodes within this network that are one, subject to very heterogeneous regulations (as I'll talk about later), but two, have to work with banks in order to deliver payment services to their customers. Banks become an important intermediate product, because banks, and banks alone, have access to the core clearing and settlement infrastructure.

This creates two issues that I'm going to talk about in a moment. The first one we've already talked about today, which is the cross-sectoral risk between a Circle, for example, and an SVB (Silicon Valley Bank) during times of institutional or systemic stress. The second is that the banks that Venmo, PayPal, and Circle work with now become strategic choke points that become, or can create, barriers to competition in the market for money and payments.

Ultimately, the system I've just described (in very, very simplistic terms) is one that is also still evolving, and it may be the case at some point down the road that we see a fundamentally different network structure in place, a full peer-to-peer system. I'm going to put this dream aside for the moment and focus on what we have, which is an evolving network structure that now has both primary and peripheral institutions, and a structure that the regulation of those institutions is very, very different—not just banks now, but non-banks falling into a wide variety of different categories.

The fundamental problems that this is creating in the system, and what I believe are the tensions that we are grappling with today, are, one, that—as I'll talk about a little bit later on—we're actually really good at regulating banks in a way that ensures that their monetary commitments are good money, and I'll define that for you in a minute. But for all sorts of reasons that I'm happy to talk about in Q&A or with David's questions, banks—especially in the United States—have historically not been at the cutting edge of payments.

This is for all sorts of reasons. The US banking system is very diverse, and very large. The CapEx (Capital Expenditure) investments that banks made going back a generation, in response to things like Y2K and the merger boom of the late '90s and early 2000s, are still impacting the technological architectures that they have to live with today. But the reality of the matter is then that the conventional banking system gives us good money, but often not great payments.

The reverse of that is that, after the creation of commercial APIs (application programming interfaces) in 2001, we get this boom in non-bank payments, where these are technology-driven institutions, fundamentally. But, because they're not banks, and they're not subject to bank regulation, the money that they create, the monetary commitments they create, are often not good—and I'll talk about the GENIUS Act and its impact on how close or far away we are from having good money in the stablecoin ecosystem in the United States in a moment—but the observation is simple enough. We have a set of firms that, in the inverse to banks, provide us with good payments, but not good money.

The essential problem is, then, if people choose their monetary instruments on the basis of how good they are at making payments, that we should expect to see more and more money be driven into bad money, because people value good payments. I can get a cheap payment today. I can have a convenient payment today. Venmo will let me cut a rent check or a restaurant bill today, and the implications of bad money are always in the future.

Sure, my institution can go bankrupt. Sure, there can be runs; but that's something that seems theoretical and tomorrow. And because of the immediacy of the payment function, it may be the case that people are sacrificing, in the current system, good money for good payments—meaning that the policy challenge is to bring those two things back together, to combine good money and good payments.

A little bit about what I mean when I talk about these two terms—and I think the things that, certainly in my book but also in conversations, seem to be the most valuable contribution here are that when we talk about good money and good payments, we're fundamentally talking about two different things. And I'm struck by how the debates around the GENIUS Act focused on good money, which is the thing we already have, and not good payments, which is the thing we don't have. And I'll talk a little bit more about that in a second.

But good money really just comes down to a stable nominal value, and the fact that people use it to make payments. And in a world of credit-based, bank-based money, the way that you do that is through laws and institutions, through prudential regulation and supervision, and the financial safety net.

That is vastly different than what it takes to make good payments. In a technologically-driven world, what makes good payments are the technology itself, how you design the network architectures, and then—importantly—the governance of those payment systems (who makes decisions about payment network design, and ultimately the type of payments that we see in the real world). And what we're looking for is not stable nominal value, but we're looking for things like cost, speed, convenience, accessibility, interoperability—a fundamentally different set of benchmarks than what we traditionally think of in the world of money.

This leads to a framework, in effect. We already are pretty familiar with the left-hand side of this framework in the banking system. It's all about bank chartering, prudential regulation and supervision, and the financial safety net: deposit insurance, lender of last resort facilities, and special resolution regimes.

On the right we also have a blueprint, although in the United States it's not one that we've historically pursued with any degree of policy vigor. This includes things like non-discriminatory access to infrastructure, the rails upon which the trains ride—that includes things like interoperability rules, open finance protocols, and ultimately a governance structure that works, that brings together the various stakeholders within the system, and makes decisions in the public good.

Over the next several days, if you don't see me in between these sessions, it's because I have several hundred exams to mark. So, I thought I would give us some grades, to help understand the state of play in the US. I think in general we do a pretty good job of regulating bank-based money in the United States. I'm never going to give anybody A's, because then we'll get complacent; but there's some good A's here. And at the same time, as we see with things like the Silicon Valley Bank debacle a couple of years ago, there are continually things that we can still learn about how to ensure the credibility of our monetary commitments without, hopefully, generating the moral hazard that's often associated with the overreaching of those commitments.

At the same time, the US has not done a good job with payments. I'll talk about this a little bit more in a moment, but in the payment space, both we have traditionally kept the closed network system in place by offering access to core infrastructure to nobody other than conventional deposit taking banks. As a result, we haven't had to deal with issues of interoperability across different types of institutions and networks.

Open finance, at least beyond the market-driven initiatives by firms like Plaid and Finicity, has been a complete failure. It was mandated under the Dodd-Frank Act in 2010, and more or less abandoned with the recent election in 2024. And payment network governance has largely been a matter for the Fed, which has been great for the stability of that system, but not so great for consumer welfare and innovation, and ultimately competition.

We can take this template, then, and extend it out to the non-bank world. And really, the primary purpose of my book is to illustrate that a lot of the new non-bank institutions that exist in the world are software companies first, and financial institutions second. And so, we can imagine a world in which we remove intermediation from the equation, to lesser or greater degrees, and then make sure that these institutions—like conventional, deposit-taking banks—are not subject to the strictures of bankruptcy.

Bankruptcy is the kryptonite of money. It slows things down; it stops payments. Any institution that is subject to basic bankruptcy is not going to have strong monetary commitments in times of institutional or financial distress.

But again, on the other side of the ledger—exact same templates as I described earlier on. We want to enhance competition; we want to make sure that whoever's making decisions about our payment networks are making it in the public good.

Before the GENIUS Act in the United States, the left-hand side of this equation was an absolute mess. Fifty states, fifty state money transmitter laws; a few states were moving forward with things like the New York BitLicense—all of which were extremely heterogeneous, allowed varying degrees of often quite risky financial intermediation, and importantly, all of which subjected firms to basic corporate bankruptcy law, ultimately undermining the credibility of their monetary commitments.

So, then we get the GENIUS Act. The GENIUS Act has done some good but notably left some things on the table. I want to not go through all of it, but just a couple of quick hits.

One, B- for creating a payments charter. Why on earth we would create the first federal payments charter, and then exclusively make it available for a specific type of technology at a specific moment in time, is beyond me. I'm perfectly happy that distributed ledger blockchain firms can use the charter, but why conventional entities like PayPal or Venmo couldn't, is beyond me as a policy matter.

We are conferring an advantage on a particular technology that we don't know where it's going to lead. And we don't know, in the context of future technologies, how that's going to play out. Put simply, we violated the principle of technological neutrality in the way that we've drafted the GENIUS Act.

Second, we didn't get rid of the kryptonite of money. GENIUS Act issuers are still going to be subject to conventional bankruptcy—and in fact, the GENIUS Act does a very poor job of understanding the unique elements of stablecoins, and how they mess with the legal logic of bankruptcy. Is it a contract? Is it a bare instrument? Is it some other third thing, that we're only just beginning to understand? The answer to that question has huge implications for bankruptcy. And the answers are likely going to come during the failure of the first stablecoin issuer.

At the same time, note that through all of this, nothing happens; my grades don't change on the payment side whatsoever. That's because we haven't changed anything in payments. If the benefits of stablecoins come from superiority in payments, then it's not clear to me why we didn't take the opportunity under the GENIUS Act to look at things like open access rules, interoperability requirements, and to fundamentally change the governance of our payment ecosystems.

All right; that's the report card. I'm going to stop there, except to say what I'm looking at as we move ahead with an imperfect GENIUS Act. And a lot of innovation [is] taking place not only within the digital asset universe, but adjacent to it, using more conventional technologies.

One is the promise and perils of tokenized deposits. The promise is that it's a deposit. It's good money, and if tokenized might deliver more effective payment ecosystems—not just in terms of speed and cost, but also in terms of the ability to build things on top of the payment rail, because of greater interoperability and things like the application of open finance.

The perils, on the other hand, are the fact that this is going to require an enormous amount of coordination across banks (both large and small), between banks and the non-bank sector, and ultimately, with the policymakers who oversee those institutions. We mentioned earlier cross-border payments; I think this is where, for example, the stablecoin ecosystem will live or die.

Cross-border payments are broken. The number of payment corridors that are being serviced globally has decreased dramatically over the last 15 years. The costs in the remaining corridors have gone up, not down, despite the technological revolution that we've experienced.

Some of that is understandable changes in money laundering and terrorist financing regulation. Some of that is that the institutions at the heart of the system are not well placed to capitalize on new technology, hence giving rise to the opportunity for stablecoins. Along the same vein, in all of our conversations about the monetary dimensions of stablecoins and whether US dollars will ultimately be what drives the stablecoin ecosystem, or US dollar-denominated stablecoins, there is an unbundling taking place of the money and the rails.

It seems increasingly clear to me that China doesn't care that US dollars flow through its emerging payment systems. It wants to control the rail. It wants to be the one that ultimately is able to control access to the types of firms and currencies that run on that rail, giving it a form of geopolitical power that I don't think the US has fully come to terms with yet.

And last but not least, whatever we're doing, we need to make sure that what we're doing in payments is also reflected in what we're doing in other core financial market infrastructure. In particular, clearing and settlements where, if we're not moving forward at the same pace, in the same direction, we're going to find frictions that, ultimately, we were trying to eliminate.

Sorry for going over my time slightly, gentlemen—and Carolyn—but that's it for me.

Wessel: Thanks. Carolyn?

Carolyn Weinberg: So, I was asked to bring this to life from a practitioner's perspective, so I put a few slides together to talk through what we're seeing at BNY, and how our clients, the ecosystem, and capital market transformations are taking place, and how the rails at BNY and across the ecosystem are transforming to meet those needs.

And I just want to level-set, just to remind everyone: BNY (or, Bank of New York), we are predominantly a storage and mobility firm. We hold in custody about $60 trillion in assets. We make about $2.5-3 trillion of payments every day. We are the largest clearing and settlement firm, from a Treasury perspective. We settle and clear about $20-30 trillion of Treasuries every single day.

And we do many more things like that, but we are basically an infrastructure firm, from the financial markets' perspective, so we see (obviously) a lot of the market. We also touch about 20-30 percent of all securities transacting every single day. So, that's the vantage point by which I am sitting, and I will share my remarks about what we're seeing in the markets, as well as what we are doing to enable this transformation for our clients.

So, first and foremost, it's important to know that the world is changing. Capital markets are moving faster, and that's both a retail perspective—we saw the example of PayPal and Venmo. Everyone's making payments on the weekends—that's pretty exciting. You see Robinhood; you see others enabling the purchase and sales of securities on the weekends. You have this whole retail market and model. You also have the markets that are taking place that are outside of digital—so obviously, Bitcoin and other transactions are both institutional and retail—but you're seeing this 24/7 market happening in the retail side, and that's bleeding a bit into institutional.

From an institutional perspective, when you started putting Bitcoin and 24/7 markets inside an ETF (exchange-traded fund), you started to see players like Jane Street and others making markets around the clock. So, someone referenced, I think Francisca referenced, ETFs; what's happened quite often is that one market moves another market, and in this case here we're seeing institutional players—macro in particular, but also those providing liquidity for markets—connecting and offering weekend market making.

So, macro traders: there's news on the weekends. They're wanting to trade; now there are more things to trade, therefore there's more activity. So just overarching, we're seeing 24/7 markets happening more and more from a capital markets perspective—again, in the retail and the institutional perspective.

So, when you're buying something on a weekend or you're buying something, where are you doing that? Generally speaking, we talked a little bit about stablecoin, but you need a cash leg. You need to buy it with something.

So, back in the day there were like pebbles; obviously we have dollars, but credit cards, and ultimately stablecoins, tokenized deposits, and this digital cash leg, if you will (could be money market funds). Those are used to make those payments on the weekends, or 24/7. So, all that's happening is someone wants to buy something, and you need to buy it with something that has stable value. So, we're seeing more and more this concept of digital cash on the rise.

So, first, why do we care about the fact that capital markets are evolving, and these big trends are making it possible to transform the future markets? So first, as I mentioned, we're now actually having this conversation, which is super important. Blockchain technology is no longer a bunch of people in the corner talking about Bitcoin, or something else. This is actually about market infrastructure, and an "always on" ledger enabling a lot of these things.

Second, as I mentioned, cash and cash equivalents. You have something to make the payment with—and then interoperability. Dan talked quite a lot about this, and Scott from Coinbase mentioned that fiat is moving digital or tokenized. So, the idea that the entire market of traditional assets could be, in theory, tokenized or enabled to be transacted or moved 24/7, means that the traditional fiat world and the digital world need to come together, and that's that interoperability we talk about—traditional and digital.

But all that's really happening is that that asset sits somewhere. If you wanted to tokenize something, all you're really doing is representing the books and records of that thing on a blockchain that doesn't shut down. We all have computers; they have batch processing, they shut down. Digital ledger do not. That's the biggest difference, so it enables that.

And then regulation as a catalyst; what's really important, while there may be some challenges or some non-perfections in some of the regulation, nonetheless, we see it as a huge benefit. Having clear guard rails of where to move enables our clients to move, and therefore the world improves. And actually, there's a huge opportunity set for new players, as well as traditional players, to enable that market. So, for us, we call ourselves "on a mission" to build the financial market infrastructure for the future—so, doing what we do today, but leveraging this amazing new technology that exists.

So again, as I mentioned, we do storage and we do mobility; so, we hold assets—$60 trillion in custody—but what's happening more and more is people want to move those assets faster, for various reasons (either for collateral purposes, or to just literally do that trade on a 24/7 basis). And that has to be powered by two things: one, a digital market infrastructure—but also, we call it a "financial intelligence layer."

I just want to pause for a second. When you put some books and records on a blockchain (and it could be private permission, which is what we do), it enables the ability to program that. And that's very important. That payment has to go out at this time. It is programmed.

So, that ability to have a financial intelligence layer is not just the pricing of whatever it is, but the books and records sit somewhere. So, when you see the future state of capital markets, they will evolve because you're going to be able to program. When you ask our clients, "Would you like to tokenize something?" They say, "Maybe; I don't know." But if I say, "Would you like certainty of settlement?" The answer is, "Yes." And that's the key thing.

This is not about tokenization, per se. It's about this financial intelligence layer to say, so and so has the cash here, so and so has the security there, and we can settle that because we have that financial intelligence to know—in a system that's on a blockchain that does not shut down—that the assets are there for this DvP (delivery versus payment) settlement, or for the cash for a trading settlement. So, again, this financial intelligence layer is critical for all of this to happen.

So again, we say that the cash market is evolving; it's really very much because you need to pay for something. So, that mobility is powering that storage, if you will. And you could do it with cash. Stablecoins, tokenized deposits, and money market funds are the predominant mechanism by which this happens.

Clients, as I said, they're really asking for a faster, always on, and more efficient way to move capital. No one is asking us to tokenize things, but they're asking us for that. Would you like faster settlement? "That would be great." Would you like programmability and certainty? "Absolutely." Would you like to use your collateral more? "Sure." These are all very normal things, and this market enables us to do that.

So, why is there this transformation in cash? And Dan talked a bit about some of the traditional rail situations, and the potential for what you can do in digital—and again, there's nothing wrong with the traditional rails and systems. And I wanted to stress, I feel like it's like "Austin Power" moments sometimes, when we're in these conferences and someone's like, "Our blockchain settles billions of dollars every day." And I'm thinking, okay, well, BNY settles $20-30 trillion in Treasuries every day.

So just to be super clear, what we're focused on is resilience and maintaining what works really well, and enabling and extending what we do very well for that stability. So, we are not saying we are taking old rails and new rails—I actually just call them "scaled systems," or "traditional" and "scaled"—that work really well, and we need to keep that. But if we needed to extend ours, we do. We are extending our existing systems, and at the same time we are enabling the blockchain, which is always on.

So, the reality is that future state is this complement, or I say something is like a concert between traditional and scaled systems that work really well with new technology, like the always-on blockchain, to enable this. One does not go away anytime soon.

At the same time, if I say, "Would you like near instant settlement?" Actually, that's like the book transfer, also. So, these things exist. "Would you like FedNow?" It exists. So, it's fascinating how it's not like the old systems are going away. The scaled systems work—and in concert with always-on blockchain, it's pretty remarkable what can happen.

So, this interoperability piece is super important for BNY to power our clients and that ecosystem, because when you think about this concept—we said digital cash, tokenized deposits, tokenized money market funds—Treasuries is a key piece of that because they sit inside everything, and then stablecoins. And again, it's almost like an ETF (exchange-traded fund); create, redeem—deposits, money market funds, and Treasuries, all into stablecoin and back again.

But actually, within our system—imagine if someone, one of our clients, says, "Hey, I'd love to use my Treasury sitting here for collateral over there, or move it immediately," or "I have some other assets that I would like to collateralize, or put into triparty." If we connect the systems together, we can enable our clients to do more with their money. So, this interoperability of cash collateral and payments is critical to that future state.

Some examples: if you're optimizing your cash balances—again, you don't have to say "tokenization;" it's almost like the jazz hands, it's really just, "Would you like to optimize your cash balances?" "Would you like to unlock your collateral?" "Would you like to move cash faster?"

And then, enabling on-chain investments; there are a whole host of people who are already on chain, and if you're already on chain, in some fashion it's—you have Bitcoin, and you have stablecoin. You've got no yield in a stablecoin, and you've got a pretty risky asset over here.

So, what's happening is those who have made a lot of money in Bitcoin are wondering, "If I had a more balanced portfolio, what would that look like?" But they're such believers in being on chain, that they would like to have some investments on chain. And that's that last piece here, and we're enabling that just like we do for traditional markets.

So, deposits we talked about that very briefly. Dan raised it. It's a critical piece of this ecosystem. Again, we have a private permission chain. Our deposits are our deposits, as many know, they are not just sitting out there for others—and inside the house is really important to consider. But inside of BNY, as you saw on that page, is an entire financial ecosystem, and where our job is to enable all of our partners, and the ecosystem that we support, to do what we're doing as well, and interconnect with what we're trying to do.

So, you'll see here this on-chain connectivity—and in fairness, the reality is we will leverage the existing rails of the system to enable all of this. Similarly, as I mentioned, stablecoins are a combination of cash, Treasuries, money market funds, and other things. And there are plenty of roles, and we play all of those to enable the stablecoin issuers.

It's very important to understand this interoperability of cash inside of a bank into a stablecoin, because that's what sends it out of the firm. Inside the firm, tokenized deposits; outside the firm is a stablecoin. And in theory, that's why you'll see, in practice, there's a lot of money market funds that are starting to be tokenized, partly for investment purposes, partly to be put inside of stablecoins because that's an easier mechanism.

But also, if I said to someone, would you like a stable NAV (net asset value) issued by a very reputable firm, and it has the potential to be transferred—would you like that, with yield? The answer is yes. So, this is all about use cases. It's not about this fancy new world. It's just, there's a lot of demand, and how do you meet that demand?

So, with that, I'm going to pass it to our next speaker. Thank you very much.

Wessel: I'm struck by the . . . this is progress. For generations, our ancestors fought to have us a weekend, and now we've got technology which will destroy the weekend.

John Schindler: All right. Thank you, everybody, for being here today. Thank you for the organizers, for inviting me to speak here today.

I think there's a little bit of a risk whenever you invite the Financial Stability Board (FSB), especially when you invite us to a really sunny, beautiful location like this, because there's always the risk that I stand up here and talk about all the horrible things that we think might happen to the financial system, or might happen as a result of crypto assets and stablecoins. But in honor of the generosity of our host, I'm going to talk more about the work that the FSB has been doing over the last ten years or so.

So, what I have on the screen here is a timeline of the FSB's work over roughly the last decade. If you look on the left-hand side, 2018 is roughly the first time that the FSB published anything on crypto assets or stablecoins, and that initial work was very typical of the way the FSB does things. It's an assessment of crypto assets and stablecoins. What are the benefits of these innovations? What are the potential vulnerabilities?

And one of the things that came out of that very early work was an understanding that there certainly are benefits and risks, and we talk about the benefits; we don't just talk about the negative sides. But there was an understanding of our membership—seventy members, two dozen countries, central banks, financial regulators of various sorts—which was that there were enough benefits and enough momentum towards adoption that we needed to take a few steps, and the first of those was we need a comprehensive framework for crypto assets and stablecoins.

"Comprehensive" in the sense that you can't just think about financial stability; you have to think about investor protection, you have to think about the macro financial, the monetary policy, AML/CFT (anti-money laundering/countering the financing of terrorism). You need a comprehensive framework, because they are being adopted at such a rapid rate.

The second thing you needed is you needed consistent global implementation of that framework—consistent and global. "Global" in the sense that these things move around, and you can't just say, "Well, my jurisdiction's fine, so I don't have to worry about this." They will locate wherever they can find the best situation. And consistent, because we don't want people arbitraging where they're going to locate because they get a better deal in one place or another.

And the third aspect that all of our members agreed on was that things are changing very rapidly in this space. So, we need to monitor the developments on an ongoing basis, and we need to cooperate. Because what you're seeing, I'm going to see, if I haven't seen it already.

So, in 2023, at the request of the Indian G20 (Group of 20) presidency, this comprehensive framework was put down on paper for the first time. So, we worked with the IMF (International Monetary Fund), we worked with FATF (Financial Action Task Force), we worked with other groups, to develop that comprehensive framework.

Subsequent to that, we've been working on those last two elements—the consistent global implementation, and the monitoring. The final report you see there in 2025 (it's only seven or eight months old now), was our first attempt to look across the globe at where people were in terms of implementing the recommendations that were a part of that framework. So, I'll talk a little bit about that here.

There are four things I would highlight from that report. The first thing is that an incredible amount of progress has been made in implementing the global framework. If you look, there are about 70 different jurisdictions that participated in our review of this. And I didn't show a picture that shows who's fully implemented, who's in the process of implementing, because even in the seven months since then, so much progress has been made, it would be unfair to some of those who are in that "not quite there yet" category. But an incredible amount of progress has been made.

But highlight number two, is that it's not enough. We are looking for global implementation. If a few jurisdictions don't implement, that's where the firms are going to locate their assets. That's where the firms are going to try to get the best regulatory treatment. And highlight number three, the implementation has not been consistent, or as consistent, as we would hope. As a result, there's potential for regulatory arbitrage here. We don't want that fragmentation, so we still have some progress to make.

But that final highlight there, I think is the most important. And that is that cooperation is so critically important here. I was at a regional group—the FSB has six regional groups, scattered throughout the world—I was at a regional group in Asia sometime last year, and we were talking about developments in crypto assets. And one of the members was talking about a development in their jurisdiction that they were concerned about. A couple of people around the table were saying, "Yes, I agree; that's very concerning."

The co-chair said, "We haven't seen that in our jurisdiction yet, so I'm glad you brought this up; but we haven't seen that yet." And we all went off to a break, or lunch or something like that; we came back from break and the co-chair says, "I was concerned about that development you guys were talking about, so I called my team during the break and they said, in fact, we are actually starting to see that in our jurisdiction." So just the fact that things are changing so quickly, he didn't even realize this had come into his jurisdiction at that point in time.

So, thinking about stablecoins a little bit more; let me tell you what we're doing now. So, we are doing some of the work on vulnerabilities (so that first bucket there, the analysis of stablecoin vulnerabilities). A couple things that people have raised as potential concerns; one is the stablecoins that are issued in multiple jurisdictions. Given that the framework has not been implemented consistently around the world, there is this potential for different redemption terms in different countries. So maybe you would choose to redeem in the country where you have the best terms. So, we're looking into that in a little bit more detail.

There are also questions about the data. Authorities want to know, "Well, what data do you collect? Do you collect the same data? Well, I should probably be collecting that same thing. How are you monitoring the vulnerabilities?" Or, in terms of stablecoins, in terms of the reserve assets, I think Francesca showed a chart with Circle and Tether and what they were holding. People are asking questions about, "Well, how much are you requiring of this, that, or the other thing?"—so, looking at some of those issues.

That second bucket is working together on supervision. It's not a bank issue; it's not a non-bank issue. All the members of the FSB are dealing with crypto assets and stablecoins, and so sharing how different regulators and supervisors are working with the various issues and learning from each other is a big part of what we're doing.

The third bucket is the implementation. We'll continue to work on that. As I said, we're looking for consistent global implementation. We're working with the IMF, the World Bank, the BIS (Bank for International Settlements) through FSI (Financial Stability Institute) on technical assistance and training missions around the world. And then we're also doing country reviews. This year, the Republic of Turkey has agreed for us to come in and review their own implementation of the stablecoins framework, so we'll continue to work on that.

And I just wanted to say a few words on cross-border payments. I think Dan gave some thoughts on where we were in cross-border payments, and the G20, I think, agrees. You were talking about the United States, but the G20 agreed that we need to make payments faster, cheaper, more transparent, more accessible.

So about five years ago they asked the FSB to coordinate a roadmap, and that roadmap involves the work of the FSB, the BIS, various parts of the BIS, IMF, World Bank, FATF, and others, to try to achieve some of those goals. Now an important part of this, an important question people have asked is, "Well, can't stablecoins be a part of this?" And that roadmap, which was put out about five or six years ago, as I said, had, even back then, envisioned a role for stablecoins.

And I think Andréa Maechler is here; I saw her earlier, I think, through the light. I can't . . . she's right over there? They have been tasked with doing big parts of that work on stablecoins through the innovation hub there, through the CPMI (Committee on Payments and Market Infrastructures), which is housed at the BIS. The FSB continues to coordinate that roadmap, but there is possibly a role for us, here.

And, anecdotally, I live in Switzerland now, but I have family still here in the United States, and I now have a great app that lets me send money back to my family. It's great, and some of my colleagues were telling me, "Well, have you tried this app or that app?" I was like, "I'm not so sure about this. I like this; it's more traditional." And they said, "Well, you know that they use a stablecoin underneath that now." I was like, "No, I didn't know that." So, I'm actually already using stablecoins for cross-border payments, and I had no idea.

Finally, tokenization; another development here. The FSB put out a report in 2024 looking at the benefits and the potential vulnerabilities from tokenization. At the time—this is 2024, two years ago; but I'd say take this with a grain of salt, because a lot of time has passed—we said there were limited financial stability risks. The uptake was just very limited. I think we wrote about tokenized repo, which was active in a few banks. I hear Carolyn talking about the work with tokenized deposits; at the time, we couldn't find anybody who was doing anything other than prototyping this. So this is a potential for a significant increase in the use of this technology, which would have potentially profound impacts, some positive and some negative.

And I'm going to stop there. Thank you.

Wessel: Thank you. Let me remind you that you can use your app to ask questions. If you can't figure out how to use your app, if you wave your hand mildly, I'll violate all the rules of the Atlanta Fed and call on you. I wonder if we could just start where you left off about tokenization. Carolyn, maybe I can ask you.

So, on one hand, the people who are advocates of stablecoins have enumerated all the advantages that we've talked about, and I've heard this. There was a bit of talk of incumbency risk before. I've talked to some people in this space, and their basic argument is, the banks are idiots. They have so much legacy technology, there's no way that they can survive us, and they'll just become like, you know, paperwork processing.

And then I hear from somebody like Jamie Dimon, who doesn't seem inclined to say, "Well, I'm just going to let my business erode." And so, is there a chance that tokenization will actually become a much bigger force, and that the growth of stablecoins will be constrained because some people will prefer to have a tokenized bank deposit than Tether or some other stablecoin?

Weinberg: So, I think we're starting to be in a world where digital cash is growing, and the adoption of digital cash, broadly; so, an entire market is growing. And in that, we're going to see stablecoins, tokenized deposits, tokenized money market funds, and I would even put tokenized Treasuries in that bucket as well. Because we'll see more and more, from a collateral perspective, that blurring of use case, from payments to settlements to collateral.

So, I deeply believe that many banks—or most banks—will start to evolve and embrace tokenization, from the perspective of "always on." I think there's a myth around big banks; our systems are old and terrible, we've been regulated, somehow you guys still like us. We make trillions of payments every day, and we settle tens of trillions of securities every day, so it works really well.

At the same time, we all have to evolve. And if our clients are looking for an always-on system, and at the same time we are actually powering a lot of the stablecoin companies. So I think that Dan had a really lovely picture that had, here are the banks, and actually the bank—I think it was actually publicly this—Circle's reserve cash is at BNY. They need a bank to make the payments, to do all of these things.

So, at the same time, if we don't evolve our systems to enable 24/7, that's a problem when the market is moving that way. So, there is this evolution and a massive increase in digital cash, while at the same time, it's not stablecoin or deposits or Treasuries or money market funds, and maybe some other things. It's actually all of it, growing to enable the ecosystem to grow.

Wessel: Just to be—for the 101 here—the reason I want to have a tokenized Treasury or a tokenized money market fund is so I can use it instantly to buy something, essentially the same way I can cash.

Weinberg: So, tokenization—again, I joke with people, "It's like jazz hands; it sounds super fancy." The question is, would you like to store your asset with BNY so that you can use it when you want, or not? Would you like it in normal hours, or would you like to extend the hours for optionality? If you'd like extended hours for optionality, we will represent that books and record on the blockchain that's inside BNY, and it will always be on. That's literally all that's happening.

And Dan and I were talking earlier, there are lots of layers and levels to tokenization—private permission, public, all sorts of elements, predominantly at scale from a resilience and safety perspective. We're focused, and our clients are focused, much more on inside BNY, and the ability (to the extent needed) to go outside of BNY, and that's another element of interoperability.

At the same time, this is much more about at-scale enabling. So, yes, the reason why I put Treasuries in there is because when you look at collateral movements. It's about Treasuries and cash—and payments are really about those two things. And then secondly, when we look at the emergence and the growth of stablecoins, if you just imagined—and I think Francesca called it a "money market fund wrapped in a stablecoin that gives no yield"—something like this, you'd need Treasuries to move, to actually mint or create a new stablecoin. Therefore, you need the ability to have those Treasuries move, and you need to create a new one.

So, the interconnectivity between what sits inside of a stablecoin, and what actually also moves outside (or inside of a BNY, or other systems) is important. And I think you gave this great point, most people don't even know that when they're making a payment, there's a tokenized deposit behind it, or a stablecoin behind it, because those are the rails people are using. And you don't even care; you're just like, "Oh, I would love to make that payment on the—"

Wessel: Until it doesn't work. Dan, could you talk a little bit more about the D grade you gave for governance of payment systems? What are you talking about there, and what is it you think we should do that we're not?

Awrey: Sure. So, at the risk of having everybody throw their breakfast at me, the Fed has a deeply entrenched and conflicted role in payments in the US. It is the owner and operator of Fedwire. It's the guardian of the master account access, under section 14 of the Federal Reserve Act. It is the overseer of the private sector payment networks that are built around that core infrastructure.

The Fed's mandate, the dual mandate, says nothing about payments—says, arguably, a lot about financial stability. And that mandate, while extremely important, is a single mandate, for safety. And what that has meant over time, it's played a role in making the US a laggard in technology-driven payments and the evolving infrastructure. The infrastructure is evolving, but the Fed really hasn't been playing a role in that.

And you can look to something like the rollout of FedNow. I suppose I'm one of the people who, ten years ago, I loved the idea that there was going to be a public payment rail that was built on technology that would enable the type of programmability we're talking about, the interoperability with existing systems, the ability to build an ecosystem on top of the payments rail, in effect.

FedNow did none of that, and if you look at the statistics on FedNow usage, if you look at the legal framework, it was really a promise never achieved. Why? Well, you put a monetary authority, and financial stability regulator, and a bank regulator in charge of a gigantic technology project, and you're maybe not going to get the results that you want.

Similarly, if we look back to the Faster Payments Task Force from a decade or so ago, the Fed does go out and tries to engage with a broader cross section of the payments community. What happens? Well, nothing, except the creation of RTP by the biggest banks. Right after that, we get real-time payments.

Absolutely; we get real-time payments, which is now, I suppose, part of the legacy ecosystem—but it's a real-time payment rail that is used predominantly by the largest banks in the US. It is a real-time payment rail that's not available to non-banks because of the existing legal architecture, and so the D is really for having a central bank alone be responsible for all of this.

There's a role to play—and the rest of the world has learned this lesson more than the United States—there's a role to play for consumer protection regulators and policymakers, a role to play for competition regulators and policymakers, and a more concrete role for the technology industry. My point about payments fundamentally being a technology issue, not a regulatory issue, is one that exposes the potential costs of having a central bank and central bankers make technology decisions, even if it means they're ultimately just outsourcing that to other folks.

And so, in a perfect world—in a world which I'm not sure exists, but—to at least get the US above a passing grade, you'd want to open up the decision making process, have a more formal structure for making decisions about when and how to upgrade new technology, have more formal metrics for understanding whether the payment system is doing what we want it to do for people, for small businesses, for the financial system. And that's why they get a D, because we have none of that.

Wessel: Is anybody—who does it better than us, even though nobody would get an A?

Awrey: I think, one, many jurisdictions that have a stand-alone payments regulator and authority. I'm Canadian; we have a version of that that I would also give a D to, because we created Payments Canada, and then staffed Payments Canada with people from the five big banks (and Canada has just about a record in payments as the United States does).

We feel slightly better, because the only country in the G20 with a worse payment system in Canada is the United States—and as long as we beat the United States, we feel okay. Unfortunately, payments has now become our only victory, now that we can't rely on hockey as much as we used to.

But I look to the United Kingdom. I think they've done a relatively good job. I look at some of the emerging market experiments, in terms of India, Singapore, Brazil, Chile—which I just came back from a few days ago, where we have a more pluralistic approach to governance that acknowledges the fact that, in addition to the extremely important financial stability implications, there are all these other metrics that make for good and bad payment systems that go beyond simply the stability dimension.

Wessel: How did the Chinese do, as far as we can tell?

Awrey: Yes; I think that their hand was forced by Alipay and WeChat Pay, over a decade ago now. I actually think their authoritarian tendencies have worked out very well, in terms of managing an updated payment system.

The move to have the core providers, for example, deposit all the customer deposits in central bank reserves is something that I think is useful. Allowing the bolting of payment systems onto commercial platforms, thereby enabling you to effectively cross-subsidize, creating a world-class payment system because you're not making the money off the payments; you're making the money on the things that you're selling on the platforms that facilitate those payments. [These] are all things that I think have been pretty good for China.

But there are also two things that are just anathema in the United States: the separation of banking and commerce is sacrosanct here, which I think is a barrier to innovation in many respects. And then the opening up of central bank reserve accounts, which I've been advocating for years but which I think there's still a lot of misunderstanding and a lot of question marks that I have when I speak to the policy community in DC about the costs and benefits of doing that.

Wessel: Right. John, I have two questions for you. One is, can you pick up on what your conversations with the Chinese have been on all this? They look like they were good, on your little map.

Schindler: So, the Chinese, I believe, have a ban on stablecoins. So, if you look at our chart, there will be a little asterisk there saying they don't have a framework other than a ban, so it's hard for us to assess how they do.

Wessel: That's one framework.

Schindler: But they are a very engaged member overall—so, very active in our work, understanding vulnerabilities and benefits.

Wessel: Talk a little bit about how you think about the cyber risk here, how well protected we are.

Schindler: So, cyber risk is a very hot topic, given some of the recent developments (some people might have heard about some of this). I think anytime that you increase your digital surface, you're increasing your cyber risk—so, there's no confusion about that. The FSB has been doing work on cyber risk for more than a decade now, but some of the work we have done has been the work that is safest to do, in some sense.

We recently put out FIRE (Format for Incident Reporting Exchange), which is a way for institutions to report operational incidents, of which cyber incidents are one type. What we were hearing is that in the event of a cyber-attack, for example, you would have the cyber team trying to fight the attack; at the same time, they might be filing as many as 60 (or, I think it was 120) reports that one company had to file with all its regulators at the same time. So, we developed a template to hopefully reduce the number of reports there.

Now, a stablecoin provider, somebody who's using tokenization, they should be obviously very much thinking about this, and I would hope that they would have a framework in place. You're nodding, so I'm sure you're thinking about this a lot, especially in light of recent developments. So, recommendations we've put out in the past about cyber would probably all apply. If it's third party, we have recommendations on third party, as well.

So, it's a big topic. It goes way beyond this, but I think here the digital surface is complete; it's 100 percent digital.

Weinberg: Yes, I think it's really important whenever you assess, like from a stability/resilience scale perspective: What do we do well today, and how do we leverage and learn from that? And the governance from that is critical—and by that, when we look at our cyber risk alongside operations and enterprise risk, it's all connected. So everything we build and design, it's with a whole team in partnership. So, we all sit in a room and look through it.

And obviously we have loads of approvals from a governance perspective, but there's also the: how do we build, how do you create an operating model, and how do you create speed bumps? How do you create those speed bumps in a thoughtful and intentional way, to reduce these risks?

And it's very much not simply cyber, but it's cyber operating and so on and so forth, all together to really think through it. And that's where—and Dan and I talked a little bit about this before—that the technology teams, the disruptors, if you will, don't have that scaled understanding and the operational excellence around that. And of course, we're humble and we have to continue to learn and invest and focus; but it's that combination of deep expertise of the market, regulation as a friend, and this understanding of the new technologies—it's that combination.

Wessel: You might make t-shirts out here: "regulation as a friend." We could send one to Miki Bowman, and see what she thinks. But look, it seems to me there are two issues here, and I'm interested in this. One is, obviously, the cryptography is advancing very fast—the mythos thing. It's moving faster than most of the other technologies in my lifetime.

And the second thing is that you could create panic with, as you said, some small operator that probably isn't as careful as BNY, and suddenly—like we learned with the breaking of the buck of the prime reserve fund—it doesn't take much to get people terrified, especially of a technology they don't understand. So, it seems to me the risk is fairly substantial.

On one hand, the sophistication of the AI technologies, and the second because we're still sort of decentralized and disaggregated, that a bad thing in a little operator could spread to the big ones. Right or wrong?

Awrey: In a word, right. But I think that just foregrounds the importance of the governance dimension of all of this. It's not going to stop, and if we think it's not going to stop, in terms of the advance of technology and the evolving nature of the cybersecurity threat, new business models creating new attack surfaces—if we can't stop it, we have to move along with it. Realistically, we might not be able to move at the same speed, but that's not an argument for not trying to follow as best as we possibly can.

The big lesson I think from all of this is that the response to change is not to stand still, put your head in the sand, and hope it all sorts itself out. And I think that that's why we find ourselves, I think, behind now, is that for a lot of the policy community we got started late at this. And we're only getting up to pace now, with the speed; but now we also have to deal with the fact that there's this lingering gap between what we're doing in the policy community and how entrepreneurs, and white hat and black hat actors out in the real world, are actually using these technologies, and how they view the opportunities and threats.

Schindler: I just want to jump in and say, if it's the wild west in the regulatory sphere, then reputational risk is even worse: "Something bad happens, so I don't trust this; I'm getting out." To the extent that we can bring regulatory certainty and consistency, so that if something bad happens, you get, "Okay, that's bad—but okay; I trust the system." I think we're trying to move to the area where we can have small reputational hiccups that don't lead to a crypto winter, or something like that.

Awrey: I do think we have a fundamental tension that I don't think I have a solution to, which is that: If all of this innovation—or some of this innovation—works out, in ten years I'm not going to say I paid with a stablecoin. That's just the underlying technological architecture by which I transferred money from A to B. Which means that there is just money.

The problem, of course, is that if there are different risk profiles with different types of money, is that that increases the prospect of information contagion, because nobody's paying attention to the differences in that money, or the differences in the payment rail. So, they see the small blip and they think that applies across all money; "I'm in trouble." And I think this is the biggest challenge there. If we can make it work, it works; but if we can't make it work, we leave ourselves vulnerable to the—

Wessel: Explain what you mean. So, I'm pretty confident if I use Zelle to send from my Bank of America account, that that's good money, and it may be slow but it's good payment. And you're suggesting that maybe if I have a some kind of stablecoin thing, it might turn out that it was Tether and they didn't have all good assets and that money might not be good money. And so then one problem there affects the other; is that—

Awrey: So, I would agree with that, except I would say that—and admittedly, I'm going to take a guess that I'm the only bankruptcy lawyer in the room—is that it's not just about the assets, it's about what happens when the firm fails. I can have Treasury securities galore, but if I fail for operational risk reasons, if I fail because there's a cybersecurity incident, those assets are not being distributed out to my customers in anything resembling FDIC (Federal Deposit Insurance Corporation) deposit insurance.

Wessel: So, can you elaborate? You talk about that in your book, and other stuff; talk a little bit about why you're so focused on bankruptcy—and not just because you're a lawyer.

Awrey: Sure. The first thing that happens in a conventional bankruptcy proceeding is something called the automatic stay. That firm is no longer authorized to pay out any of its outstanding obligations to anyone, without a court order in effect.

And typically, before a court is going to give that order, they're going to ask a couple of questions. Whose money is this? Is it actually, in the manner of a conventional bank deposit, the bank's money or the firm's money? And there's just a payment obligation—a contract—in which case it's very unlikely that you're going to get the stay lifted, which means that now a bankruptcy process has started.

I was on the ground in 2008 when Lehman Brothers [Holdings Inc] went bankrupt. I was on the ground in 2021, when we had our 13th anniversary party for the bankruptcy of Lehman Brothers. The bankruptcy of financial institutions takes years in many cases. The recent Synapse debacle is a good example of this, where both people, if they're using it as money, are going to find that they don't have access to their money, and they may ultimately find that the bankruptcy process—because it involves lawyers, and we're not cheap—is going to eat into the value of their claims.

Put differently, that's why I call bankruptcy the kryptonite of money. Everything we think about money is, I get full value right now, right? A site deposit is a promise of that. And any quasi money that is able to achieve that in good times but is subject to bankruptcy, categorically cannot behave the same in bad times.

Wessel: The alternative to the bankruptcy regime is the resolution thing?

Weinberg: Or you work with BNY, because we are FDIC insured, and that is exactly how we think of it. And that's why we are the infrastructure for a lot of these institutional players—because, as wonderful as all these third-party technology providers are, and disruptors, they're not FDIC insured. So that whole stay, like, "Would you like your money back if we go bust?" The answer is, yes, the clients would—and not at a close-out value from today, but get the payment in three years.

But to that point, that's the major role that BNY plays in this ecosystem. To be that mature—not just bankruptcy remote, but managed around this bankruptcy stay topic, which I actually agree. I don't think it's well understood among this ecosystem.

Awrey: Yes; and I'll say this, just because this is a great opportunity. The Federal Reserve Bank of Atlanta does amazing research on consumer payment habits, and I think one of the big questions that still is outstanding to me is the psychology of these new monies, and whether people appreciate the differences. Certainly, the victim impact statements from Synapse, which were admittedly aided by some pretty horrendous marketing on the part of the fintech firms, were that they thought their money was safe in an FDIC-insured bank.

Wessel: Can you just—I know what Synapse is, but can you just explain in case people don't?

Awrey: So, Synapse was a financial technology provider. The world that we were laying out earlier is one in which there's this tension between where the good money is and where the good payments are. One of the ways that the US financial ecosystem is dealing with that is by connecting banks, partner banks, with customer-facing fintech institutions. And there are firms in the middle that are engaging in what are called integrations, that are trying to bridge the technological gap between the old and the new world of money.

Synapse was one of those firms; it went bankrupt two years ago. And as a result of that, the people who were holding money—ostensibly, through the front-end, consumer facing fintech companies—found that they were unable to get their funds that were sitting with partner banks.

And the reasons for that are many and complex—and in a non-legal audience I won't go into them—but it was the confounding of expectations that I found really interesting, because these people thought they could take out their money at any time (asterisk: some financial technology firm that I've never heard of goes bankrupt, and all of a sudden, I can't). And that's the world I worry about.

Wessel: Right, right.

Weinberg: I think what's fascinating, on that topic, is the combination of AI plus digital asset rails means that you actually now look at the entire ecosystem. And when you start to map out all of the pieces, there's a spaghetti chart of things and players and intermediaries and whatever else, and you start to see where there are challenges in the system.

And almost, it's like a blank sheet of paper—because if the disruptors are taking a blank sheet, why aren't we? And as we look at the system, we're realizing that maybe we should think about it differently for our clients, to enable faster, cheaper, better payments, a safer system, et cetera, et cetera.

So, it's this really interesting thing happening in the market, where the largest players, who see the entire ecosystem, are being forced to reevaluate all of what's happening, and reimagine it at the same time. And I think it's a remarkable moment; I call it like an inflection point in capital markets, because that example—many people didn't know that there were these players inside, and all of a sudden people are mapping out all of it.

And it's in everything; for example, I'll go back to the Treasury market. Many things trade inside of BNY; in many cases, it's just a book transfer from A to B, but price formation happens. There are about 20-something steps outside BNY. It comes to BNY, and then we just move from A to B.

But all along those steps, there's much more risk. But once it gets to us, we can settle it. And you start to see that power of tokenization, doing that and AI being like: Is the money there? Is the money there? And that programmability combined.

But it does give you the question of, do we need all of these other things out there? And, in fairness, Jamie Dimon is fabulous; Robin Vince, our CEO, is even more amazing—but we have—

Wessel: So, we have to buy Dan's book, we have to read all the FSB reports for the last 10 years, and we all have to appreciate BNY.

Weinberg: Listen to him as well? But it is this concept of that reimagining and rethinking all of that, in partnership with, frankly, the rest of the ecosystem, and our regulators. Because again, we need the guard rails and we need to do it in partnership to continue this resilience at scale with the excellence that we have.

Wessel: So, John, do you think we're moving fast enough to deal with this?

Schindler: I would say no. This is active right now, so in that sense, we should have had the frameworks in place years ago to be able to handle all this. So, I would love to snap my fingers and have all of my members have the framework in place. That's obviously not going to happen.

But I would emphasize, as I mentioned, that members (my members) are now working at a very rapid pace to put these frameworks in place—as rapidly as I've seen them implement anything. So, the sense of urgency is there, but regulation does not move as fast as financial innovation. It's just the way it is.

Wessel: Right; great. Please join me in thanking the panel. I thought the presentations were exceptionally lucid, and that's not always the case in these conferences. I'm instructed to tell you that there are box lunches outside in the foyer, and we expect you back here at 6 p.m. for the reception and the rest of the program. So, have a good afternoon.