In addition, more-targeted examinations may be conducted to review marketing programs, training materials, internal risk management reports, internal audits, and any internal investigations. In 2002 and 2003, the federal banking agencies received a number of inquiries concerning the scope, effectiveness, and impact of the anti-tying restrictions on banks.
The approach is technology-agnostic. Consequently, it became evident that systemically important stablecoins should also fall within the scope of the PFMI. As analysis showed, the transfer function of a stablecoin arrangement can be compared with that of other types of payment infrastructures.