Law Commons^™

A Deposit Substitute For Post Dodd-Frank Regulatory Policy Assessments Of Emergent Payments: A Taxonomical Approach, Eniola Akindemowo

Eniola Akindemowo

Existing stored value products (SVPs) are early prototypes of what payments and money will become: digital, disintermediated, and, possibly, neither state- nor bank-issued. The formulation of stored value regulatory policy in the U.S. has been a complicated, slow process however, producing a piecemeal scheme of broadly uneven regulations. Suffice it to say that the result of several short-term fixes has been to postpone looming inefficiencies and highlight limitations stemming from inconsistencies inherent in their use.

Past regulatory efforts have thrown a startling fact into sharp relief: The relevance of deposits, the hallowed central concept of payments jurisprudence, is undermined in …

Recalibrating Abstract Payments Regulatory Policy: A Retrospective After The Dodd-Frank Act, Eniola Akindemowo

Eniola Akindemowo

The future efficiency of the payments system is at stake. Existing stored value products (SVPs e.g. gift cards and gift card apps) are early prototypes of what payments and money will become – digital, dis-intermediated, and possibly, neither state nor bank issued. These products have defied sustained efforts to pigeonhole them into traditional categories. Significantly, past regulatory efforts have thrown a startling fact into sharp relief: the relevance of deposits – the hallowed central concept of payments jurisprudence – is being undermined in SVPs and emergent payments. What this means is that the role of deposits – the lynch pin …