Payment Stablecoins see 2% haircut under Rule 15c3-1

Rule 15c3-1: 2% haircut lets firms count payment stablecoins

Under Rule 15c3-1, broker-dealers apply standardized haircuts to proprietary assets when computing net capital. A 2% haircut treats an asset as near-cash, subject to a small regulatory deduction.

As reported by Coinpedia, staff guidance now allows qualifying payment stablecoins to be recognized in net capital with a 2% deduction rather than being excluded. This recognition is applied within the existing net capital framework.

The treatment targets payment-focused, fiat-redeemable instruments rather than yield-bearing tokens. The scope concerns broker-dealer proprietary positions, not customer assets held in custody.

Why it matters: alignment with GENIUS Act and capital efficiency

Based on analysis from PwC, the genius act defines payment stablecoins as fiat‑pegged and non‑yielding, with high‑quality liquid reserves and tailored oversight. The clarified capital treatment is broadly aligned with those parameters.

Recognizing eligible payment stablecoins with a modest haircut can enhance capital efficiency. It may narrow operational gaps between tokenized settlement rails and traditional cash‑equivalent instruments.

According to the U.S. Securities and Exchange Commission, a staff FAQ permits a 2% haircut for payment stablecoins when broker‑dealers compute net capital; Hester M. Peirce, Commissioner, said, “many firms had been treating stablecoins as if they had no capital value… ‘unnecessarily punitive’ given reserve quality.”

For firms, net capital computations can include eligible positions with only a 2% deduction, subject to documentation and controls. As noted by the House Financial Services Committee, clarity on reserves, issuers, transparency, and jurisdiction remains central for market integrity.

Compliance teams should map issuer disclosures to eligibility criteria, verify custody arrangements, and test redemption mechanics and third‑party attestations. Disclosures may need updates to describe methodology, limitations, and concentration or liquidity risks.

At the time of this writing, Coinbase (COIN) traded near 171.05 in after‑hours trading, based on data from Yahoo. Market levels are contextual and separate from capital treatment mechanics.

Eligibility and calculation details for payment stablecoins

What qualifies as a ‘payment stablecoin’ under this treatment?

Qualifying tokens are fiat‑pegged, non‑yielding, and designed for payments, with high‑quality liquid reserves, frequent transparency or attestations, and reliable one‑to‑one redemption in normal conditions.

Algorithmic or yield‑bearing stablecoins are generally outside scope. The approach distinguishes well‑backed payment tokens and requires strong disclosures and operational controls.

Before/after: 2% haircut versus prior 100% net-capital treatment

Previously, many firms treated stablecoins as effectively zero for net capital via a 100% haircut. With a 2% haircut, a $100 million position contributes $98 million to net capital.

The remaining $2 million reflects valuation and liquidity risk. Eligibility still depends on reserves, redemption, and disclosure standards.

This treatment applies to proprietary positions under Rule 15c3-1, not customer funds or omnibus custody balances.

The interpretation reflects staff guidance; formal amendments may follow, and requirements could change with rulemaking or further guidance.