NOVEMBER 2026

Consultation: Proposed class designation for New Zealand dollar-referenced and -backed stablecoins

About this consultation

The Financial Markets Authority – Te Mana Tātai Hokohoko (FMA) is considering a class designation for New Zealand dollar-referenced and -backed stablecoins under section 562(1)(c) of the Financial Markets Conduct Act 2013 (FMC Act). The designation would declare that qualifying New Zealand dollar-referenced and -backed stablecoins with certain features are not financial products for the purposes of the FMC Act.

If made, the designation would apply to stablecoins that are fully backed by funds held on bare trust at a New Zealand-registered bank, are redeemable at face value, and pay no return to holders. Stablecoin issuers relying on the designation would be subject to ongoing requirements, including that they publicly report on their reserves.

Next steps

We welcome your feedback on the designation proposal in response to the specific questions in this paper, as well as any other general comments. Please use the feedback form provided on the web page for this consultation at www.fma.govt.nz/business/focus-areas/consultation.

Note that all feedback received is subject to the Official Information Act 1982 and may be made available on our website or other external channels. See the feedback form for more information about your privacy and confidentiality options.

Submissions close at 5pm on Friday 18 December 2026. After this date, we will consider all submissions, finalise our policy proposal and, if the designation is made, work to get it in place.

This consultation is for stablecoin issuers, digital asset exchanges and platforms, financial institutions, stablecoin users, and other interested parties.	It asks for feedback on the need for, and the content of, a proposed class designation declaring that New Zealand dollar-referenced and-backed stablecoins with certain features are not financial products.

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Contents

Background 2

Stablecoins 2

Wider regulatory work 2

International approaches 3

FMA’s power to make designations 4

Why we are considering a class designation 5

Current regulatory settings for New Zealand-issued stablecoins 5

Approach to date 6

Problem statement 6

Proposed class designation 8

Our proposed approach 8

Proposed scope of class designation 8

Proposed product features 9

Proposed ongoing requirements 10

Consequences of designation 11

Other options considered 11

Questions 13

Background

Stablecoins

A stablecoin is a type of digital asset that is created, traded and stored on a programmable, distributed or centralised ledger. Unlike other types of digital assets, stablecoins are intended to keep a stable value. Most stablecoin issuers seek to accomplish this by holding a pool of reserve assets (such as fiat currency, commodities, or other digital assets) that backs the stablecoins in circulation and allows holders to exchange the stablecoins back for the reference currency, thereby allowing the stablecoin to maintain its ‘peg’ to its reference asset(s). The main types of stablecoins include:

• asset-backed stablecoins, backed by reserve assets that may comprise:

  o cash or fiat currency held in on-call bank deposits;

  o managed collateral, such as short-dated government securities, money market funds or unit trust interests; or

  o a combination of cash, managed collateral and/or other assets; and

• algorithmic stablecoins, which rely on smart contract mechanisms to influence token supply and demand in response to market conditions to keep their price close to a target value.

Our proposed class designation focuses on fiat-backed stablecoins only, specifically those backed by the New Zealand dollar (NZD). The intent is to designate this specific type of stablecoin, rather than establishing a new bespoke regulatory regime.

Stablecoins backed by a combination of cash, managed collateral and potentially other assets represent the dominant international model but are not within the scope of our proposed class designation. Algorithmic stablecoins carry materially different risks from other types of stablecoins and are generally excluded from stablecoin regulation internationally.

Stablecoins are increasingly used to move value across blockchain networks and, to some degree, make payments. Their attraction comes from a combination of predictable value and the speed, automation and lower transaction costs that blockchain technology offers. Unlike many other digital assets, stablecoins are generally not acquired by holders to earn a financial return.

Globally, most stablecoins across digital asset markets reference the US dollar (USD). Because of the desire to avoid USD exchange-rate risk, simplify domestic payments and better facilitate cross-border payments involving non-US-based parties, there is demand for stablecoins referencing currencies other than the USD. In a New Zealand context, we are aware of growing interest on the part of firms that are intending to issue their own NZD-referenced stablecoins.

Wider regulatory work

New Zealand does not currently have a regulatory framework designed specifically for digital assets, including stablecoins or their issuers. The FMA’s previous discussion paper on tokenisation in financial markets has prompted discussion about how the law should treat digital assets. It highlighted regulatory uncertainty about how existing financial markets law applies to digital assets and the case for a clearer regulatory framework.

The Ministry of Business, Innovation and Employment is currently leading policy work on potential law reform of payment services regulation, which includes considering how payment stablecoins should be treated and whether specific requirements should apply. Inland Revenue has proposed an exemption for income from the acquisition and disposal of certain stablecoins when acquired for the purpose of disposal.1 The Reserve Bank of New Zealand’s recent public consultation on modernising New Zealand’s retail payments system also briefly discusses the role of stablecoins.

Because any broader legislative reform is likely to take some time, this consultation focuses on whether a class designation could provide an interim pathway for issuers of NZD-referenced and -backed stablecoins under the current law. Given the nature and limits of a designation, we are proposing a focused approach, with broader questions about the appropriate regulatory framework for stablecoins left to any future policy and legislative work. The proposed designation should not be taken as establishing a precedent for the design of any future legislative framework.

International approaches

Internationally, regulators are increasingly developing bespoke frameworks for payment stablecoins. The Financial Stability Institute of the Bank for International Settlements2 offers insight into common regulatory themes across jurisdictions, including reserve asset requirements, redemption rights, governance and riskmanagement standards, and prudential oversight of reserve management. It observes that stablecoin issuance is increasingly being treated as a distinct regulated activity, with safeguards tailored to the operational, liquidity and reserve risks associated with payment stablecoins.

The clearest examples of this are found in the United States, the European Union, Hong Kong, Singapore and, more recently, the United Kingdom. The Guiding and Establishing National Innovation for US Stablecoins Act 2025 (GENIUS Act), the European Union Markets in Crypto-Assets Regulation (Regulation (EU) 2023/1114) (MiCA), Hong Kong’s Stablecoins Ordinance, Singapore’s single-currency stablecoins framework, and the United Kingdom’s recently implemented stablecoin regime3 each establish a dedicated regulatory framework for payment stablecoins.

Australia has adopted an interim approach under which the Australian Securities and Investments Commission (ASIC) considers some stablecoins to be financial products under existing law, while providing transitional relief as broader digital asset and payments reforms are developed.

Although the approaches differ, there is a clear international trend towards bespoke regulation of non-yieldbearing payment stablecoins, rather than reliance on traditional securities law concepts alone. In this context, our view is that transitional relief is appropriate while broader policy issues are considered.

[1] Taxation (Annual Rates for 2026–27, FBT Simplification, Foreign Investment Funds, and Remedial Measures) Bill 2026 (344-1), cl 10.

[2] Adrien Currat, Johannes Ehrentraud and Denise Garcia Ocampo Regulating stablecoin issuance: permissible entities and activities (Financial Stability Institute of the Bank for International Settlements, FSI Briefs No 33, August 2026).

[3] Financial Conduct Authority Crypto Regime: Stablecoin issuance (Policy Statement PS26/10, June 2026).

FMA’s power to make designations

We have powers to declare that a security is not a financial product for the purposes of the FMC Act.4 A designation can apply to a particular security, or to a class of securities. Before we make a designation, we must be satisfied that it is necessary or desirable to promote one or more of the following purposes of the FMC Act:5

• to promote the confident and informed participation of businesses, investors, and consumers in the financial markets

• to promote and facilitate the development of fair, efficient, and transparent financial markets

• to provide for timely, accurate, and understandable information to be provided to persons to assist those persons to make decisions relating to financial products or the provision of financial services

• to ensure that appropriate governance arrangements apply to financial products and certain financial services that allow for effective monitoring and reduce governance risks

• to avoid unnecessary compliance costs

• to promote innovation and flexibility in the financial markets.

We must also have regard to the economic substance of the security, and consult the persons, or representatives of the persons, that we consider will be substantially affected by the designation.

We can only make a designation where we are satisfied that the statutory requirements are met. We need information from you to support our decision-making, so we encourage you to provide feedback about why (or why not) a designation is necessary or desirable to promote one or more of the purposes detailed above.

[4] Financial Markets Conduct Act 2013, s 562(1)(c).

[5] At ss 563, 3, and 4.

Why we are considering a class designation

Current regulatory settings for New Zealand-issued stablecoins

Whether a stablecoin is regulated under the FMC Act depends on whether it falls within the definition of one of four types of financial products: debt securities, equity securities, managed investment products and derivatives.6 In relation to the proposed designation, we are primarily concerned with the ‘debt security’ definition7–

“a right to be repaid money or paid interest on money that is, or is to be, deposited with, lent to, or otherwise owing by, any person”.

In simplified terms, stablecoins have previously been issued in New Zealand using the following structure:

a) a customer transfers currency (e.g. NZD) to the issuer and receives the corresponding number of stablecoins in return

b) the issuer holds those funds on bare trust for stablecoin holders in an on-call account at a registered bank

c) stablecoins are transferrable between holders on blockchain networks as a means of payment

d) any holder of the stablecoin can later return the stablecoins to the issuer and receive the corresponding amount of currency back.

In our view, a stablecoin structured this way is likely to be a debt security for the purposes of the FMC Act. Deposits in a bank account are debt securities issued by the bank for the purposes of the FMC Act. A financial product of a particular kind includes a legal or equitable interest in a financial product of that kind.8 Because stablecoin holders have an equitable interest in the funds held on trust (as they have the right to redeem one stablecoin for the equivalent amount of currency held on trust), the stablecoin is a debt security.

This outcome does not reflect how these stablecoins are used in practice, as their economic substance is as a means of transferring value, such as payments, and not an investment. The financial product regime in the FMC Act is designed for products where generating a financial return or managing financial risk is a significant feature.9

Other stablecoin structures may raise different considerations. For example, some stablecoins may provide holders with a financial return or hold reserve assets in investments other than on-call bank deposits. These features may affect the product’s economic substance and raise different questions about its treatment under the FMC Act. The proposed class designation does not cover these structures.

[6] At s 8.

[7] At s 8(1)(a).

[8] At s 8(5)(a)(ii).

[9] Ministry of Economic Development Review of Securities Law: Discussion Paper (June 2010).

Approach to date

In March 2026, we declared that the NZDD stablecoin issued by ECDD Holdings Limited (ECDD) is not a financial product, under the Financial Markets Conduct (ECDD Holdings Limited Stablecoin) Designation Notice 2026 (the ECDD notice).

In making the ECDD notice, we concluded that the economic substance of the NZDD stablecoin is not that of a financial product because:

a) it is not an investment, and no income, interest or other gain is paid to holders

b) its practical use is as a means of payment or remittance

c) the reserve assets held on bare trust for holders are not a source of funding for the issuer

d) the risks of holding the stablecoin are not substantially different to the risks of holding the underlying reserve assets, i.e. deposits with New Zealand registered banks, which are subject to the Reserve Bank of New Zealand’s prudential regulation, and offers of which are not regulated offers under the FMC Act.

We additionally considered that:

a) treating the NZDD stablecoin as a debt security was unlikely to support the confident and informed participation of consumers, and was more likely to confuse them as the product is in substance a payment mechanism rather than a debt security;

b) continued availability of the NZDD stablecoin will promote efficiencies in the payments and remittance markets by increasing competition;

c) regulation of the NZDD stablecoin under the FMC Act as a financial product is unlikely to contribute to transparency and/or the provision of useful information to customers as the underlying reserve assets are not classed as ‘regulated offers’ for the purposes of the Act and so are already excluded from disclosure and governance obligations; and

d) issuing the stablecoin is a financial service because it involves issuing and managing a means of payment and keeping, investing, administering or managing money, securities, or investment portfolios on behalf of other persons, 10 so the fair dealing provisions in Part 2 of the FMC Act continue to apply.

The ECDD notice applies only while the stablecoin has specified features and ECDD complies with ongoing duties. Our proposed class designation closely follows these features and duties.

Problem statement

We are aware of a small number of other firms that are developing or considering developing NZD-referenced stablecoins with a structure similar to the NZDD stablecoin. Without a designation, those stablecoins are likely to be financial products, even though their economic substance is the same as the NZDD stablecoin.

Treating these stablecoins as financial products may have few practical implications for the stablecoin issuer in terms of additional disclosure or governance requirements under the FMC Act. The funds backing the stablecoins would be held as on-call deposits with New Zealand registered banks. Offers of debt securities issued by a registered bank do not require disclosure under Part 3 of the FMC Act, and so are not

[10] Financial Service Providers (Registration and Dispute Resolution) Act 2008, s 5(1).

‘regulated offers’. Because a stablecoin holder’s interest is an equitable interest in the underlying bank debt security, an offer of that interest is also not a regulated offer. It is therefore not immediately apparent that treating NZD-referenced stablecoins as debt securities would impose unnecessary compliance costs or regulatory burden on issuers.

However, we are aware that leading digital asset exchanges prevent listing of digital tokens that would be considered securities transactions in the relevant jurisdictions. The categorisation of an NZD-referenced and -backed stablecoin as a debt security would therefore limit issuers of such products from accessing those exchanges.

We also understand that following the ECDD individual designation notice, at least some New Zealand banks have expressed a preference for prospective issuers to obtain designations from the FMA as part of the process of opening an account for the purposes of issuing an NZD-backed stablecoin. Financial product status may therefore have significant practical consequences and create barriers for issuers, despite giving rise to relatively few additional disclosure or governance requirements under the FMC Act.

Treating these stablecoins as debt securities may not promote the confident and informed participation of consumers in financial markets. Their economic substance and intended use are as a means of payment rather than an investment, and regulation as a debt security may therefore confuse consumers about the nature of the product.

Beyond applying for individual designations, there is also currently no clear regulatory pathway for prospective issuers of stablecoins in New Zealand. This may lead to inconsistent treatment of matters such as the holding of backing assets and redemption rights, create uncertainty for issuers and risks for consumers, and undermine fair, efficient and transparent financial markets.

The purpose of this paper is to seek feedback on options to deal with these problems, and the costs and/or benefits of making or not making a class designation. This will help us determine whether a designation is appropriate in view of the statutory test and the purposes of the FMC Act.

Limitations of continuing with current approach

One option available to us is to continue considering individual designation applications from issuers. We do not favour that option for three main reasons:

• it increases cost and time to market for issuers if they need to apply individually for designations for products with the same economic substance as each other, and is not an efficient use of FMA resources;

• it could result in uneven treatment of economically similar products, depending on whether and when an issuer has applied; and

• it does not give certainty to potential new entrants about the settings that apply to NZD-referenced and -backed stablecoins – certainty was a key recurring theme in feedback on our previous consultation on tokenisation in financial markets.

Proposed class designation

Our proposed approach

One of our main aims in proposing a class designation for NZD-referenced and -backed stablecoins is to promote innovation and flexibility in financial markets. However, given our intention to provide only an interim pathway ahead of wider legislative reform, we propose a focused approach for this class designation that is closely aligned with the ECDD notice and a conservative stablecoin design with reserves held dollar-for-dollar in a New Zealand bank account.

We recognise that a designation is a blunt tool. It removes a product from the FMC Act financial product regime altogether, whereas a bespoke legislative regime could provide a wider range of tools, such as licensing and baseline obligations for issuers. This limitation supports our proposal to limit the class designation to stablecoins backed by simple bank deposits, rather than seeking to address, through a designation, broader questions about the appropriate regulatory treatment of different types of stablecoins.

Where a stablecoin allows reserves to be actively invested, pays a return to holders, or involves more complex treasury management arrangements, it raises a different set of risks and may begin to look more like an investment product. Stablecoins that are algorithm- or commodity-backed pose more complex challenges relating to stability and valuation. Those structures may require regulatory requirements tailored to their particular features and risks, which cannot readily be achieved through a designation that removes the product from the financial product regime altogether. We consider these structures are better addressed through future policy and legislative work, and they are therefore outside the scope of this proposal.

Proposed scope of class designation

An open class defined by product features

We propose that the designation would apply to any stablecoin that has the features, and whose issuer meets the ongoing requirements, set out below. Issuers would not need to be named in the notice or apply to the FMA. This would treat all issuers consistently and avoid the need to amend the notice each time a new issuer enters the market.

An open class means we would not necessarily know which issuers are relying on the designation. We welcome views on whether issuers should be required to notify us before they first rely on it, or to provide any regular reporting on use of any designation.

An alternative approach would be to limit the designation to issuers and stablecoins named in a schedule to the notice. Under this approach, an issuer would need to apply to the FMA and have its stablecoin added to the schedule before it could rely on the designation. This would enable the FMA to consider whether the relevant requirements are met before an issuer relies on the designation, and would retain an application process for each new issuer and require the notice to be amended as new stablecoins are added.

We welcome views on which approach should be adopted.

New Zealand dollar stablecoins only

We propose that the class would be limited to stablecoins that reference the NZD, with reserves held in NZD at a New Zealand registered bank. This matches the ECDD notice and keeps the reserves within the scope of New Zealand prudential regulation. Stablecoins referencing other currencies may raise additional issues, such as where and how reserves are held and how overseas regulation applies.

Retail and wholesale holders

Consistent with the ECDD notice, we do not propose to limit the designation to stablecoins issued to wholesale customers. Because the risks of holding a qualifying stablecoin closely track the risks of the underlying bank deposit, and those deposits can themselves be offered to retail investors without being regulated offers under the FMC Act, we do not currently consider that a retail restriction is needed.

Stablecoins issued after commencement

A designation cannot apply retrospectively. The designation would apply only to stablecoins issued or transferred after the notice comes into force.

Proposed product features

We propose that the designation would apply to a stablecoin with the following features, which are drawn from the ECDD notice. The table below sets out each feature and why we propose it:

Feature	Why we propose it
The stablecoin is issued by the issuer to an account holder in exchange for $1 NZD transferred to the issuer.	Each stablecoin is fully backed from the point of issue, and issuance is subject to the issuer’s customer onboarding and verification processes.
The stablecoin is backed by the issuer, as trustee, holding the $1 NZD on bare trust for the stablecoin holder in a trust account at a New Zealand registered bank.	Funds are protected by trust law and held only in an on-call registered bank account. The reserves are not a source of funding for the issuer.
An account holder may return the stablecoin to the issuer and require the issuer to deliver the $1 NZD held on bare trust, subject only to any commercially reasonable restrictions on eligibility, compliance, minimum redemption amounts, timing and fees payable that are agreed between the issuer and the account holder.	Subject only to commercially reasonable restrictions, holders have a clear right to redeem the qualifying stablecoins at face value, which supports the stable value of the stablecoin.
The stablecoin does not give the holder any income, interest or other gain generated by the issuer or a related party.	This reflects that the stablecoin is a means of payment rather than an investment. The issuer may keep interest earned on the trust account to cover the cost of providing the product.

The ECDD notice requires funds to be held in a trust account at a registered bank. We welcome views on whether issuers should be able to spread reserves across more than one registered bank, for example to manage concentration risk. We do not propose to allow reserves to be held in other assets, such as government securities or money market funds, for the reasons set out in our proposed approach above.

Proposed ongoing requirements

We propose that the designation would be subject to the following requirements, which are also drawn from the ECDD notice. The issuer must:

a) ensure that the NZD held in the trust account is always equal to, or more than, the total face value of its stablecoins in circulation;

b) publish, at least monthly and on a publicly accessible website, a confirmation that the NZD held in the trust account is equal to, or more than, the total face value of its stablecoins in circulation;

c) obtain an independent verification, at least annually, of the NZD held in the trust account compared to the total face value of its stablecoins in circulation and publish the results; and

d) issue a statement on its website that its stablecoins are issued in reliance on the class designation notice.

The ECDD notice does not specify who may carry out the annual independent verification. For a class designation, we are considering whether to set minimum requirements, such as the verification being carried out by a qualified auditor under a recognised assurance standard. This would give assurance that the verification is carried out in a consistent way across products, but could also impose additional costs. We welcome feedback on this, and on the appropriate assurance standard that might be used for this purpose.

Consistent with the ECDD notice, we propose that the designation would not apply to an issuer’s stablecoins during any period in which the issuer fails to comply with one or more of the ongoing requirements. During this period, the stablecoins would be treated as financial products under the FMC Act. This gives issuers an incentive to comply, without requiring us to take separate action to remove the benefit of the designation. It also enables issuers to remedy a failure to comply with any of the requirements.

We welcome views on whether the proposed requirements above are sufficient, as well as views on any additional conditions that may be desirable, such as requiring:

a) issuers to give holders minimum information about key terms, including redemption rights and fees;

b) for the benefit of retail holders, statements to clarify that the stablecoin is not a bank deposit;

c) pre-launch and/or ongoing capital reserve requirements that mean issuers have an appropriate financial buffer to absorb unexpected operational losses without needing to draw on the reserve assets held to back their stablecoins; and

d) issuers to be registered on the Financial Service Providers Register and (if provided to retail clients) be a member of an approved dispute resolution scheme. 11

Consequences of designation

If the designation is made, qualifying stablecoins would not be financial products for the purposes of the FMC Act. The designation would not affect:

• the issuer’s obligations as a provider of a financial service, including the fair dealing provisions in Part 2 of the FMC Act, registration under the Financial Service Providers (Registration and Dispute Resolution) Act 2008 and, where applicable, the requirement to be a member of an approved dispute resolution scheme under section 48 of that Act;

• the treatment of the reserve assets, which remain debt securities issued by New Zealand registered banks; and

• obligations under other legislation, such as the Anti-Money Laundering and Countering Financing of Terrorism Act 2009.

The designation would not be an endorsement or approval by the FMA of any issuer or stablecoin.

Individual designations may still be appropriate in limited circumstances, for example where a stablecoin falls outside the scope of the class designation but its economic substance may nevertheless support an individual designation.

Other options considered

We have considered other options.

One option is to grant a class exemption from specific FMC Act requirements where applicable, such as disclosure and governance obligations, while the stablecoins remain financial products. We do not favour this option because it would not reflect the economic substance of these stablecoins as a means of payment, and could cause confusion for holders about the nature of the product.

As detailed in the problem statement above, we also considered the option of continuing to accept individual designation applications from issuers as and when needed. We do not favour this option as it would not be efficient, could result in uneven treatment of similar products, and does not promote certainty.

Another option is to design a broader class that also covers stablecoins backed by other types of reserve assets or that pay a return to holders, which would give more issuers access to the designation. However, as noted in our proposed approach, these features raise different risks and look more like investment products. We therefore consider they are better addressed through wider policy work.

[11] Issuing a stablecoin to retail holders is likely to be a financial service, so issuers will generally need to be registered in any case. However, this requirement may provide additional clarity.

A further option is to take no action while wider policy and legislative work is in progressed. However, wider reform is likely to take some time. In the meantime, this would leave issuers without a clear pathway and continue the uneven treatment of similar products described in the problem statement.

Questions

Status quo
Q1	Do you agree with the problem statement, including why the status quo does not work effectively for potential issuers of New Zealand dollar-referenced and -backed stablecoins? If you disagree, please let us know why.
Q2	Please explain the impact of the status quo on the following stakeholders. Where appropriate, provide details of the costs (including compliance costs) and any benefits. • Stablecoin issuers and prospective issuers • Stablecoin holders and users • Digital asset exchanges and other platforms • Registered banks
Q3	Is a class designation required, or are there other interventions we could consider? Please give reasons for your view.

Proposed approach and scope of the designation
Q4	Do you agree with our proposed focused approach, which closely follows the ECDD notice and leaves stablecoins with invested reserves or yield to wider law reform? If you disagree, please let us know why.
Q5	Do you agree that the designation should apply to an open class defined by product features, rather than to a schedule of named issuers and stablecoins? If you disagree, please let us know why.
Q6	Should issuers be required to notify the FMA before relying on the designation, or to provide any regular reporting on the use of it? If so, why and what information should they provide?
Q7	Do you agree that the class should be limited to stablecoins referencing the New Zealand dollar, backed by NZD reserves held at a New Zealand registered bank? If you think stablecoins referencing other currencies should be included, please let us know why and what additional conditions would be needed.

Proposed product features and requirements
Q8	Do you agree with the proposed required product features? If you disagree, please let us know why, including whether any feature would prevent you from relying on the designation if you are a prospective stablecoin issuer.
Q9	Is the proposed allowance for commercially reasonable restrictions on redemption appropriate? Should the designation set firmer limits, such as a maximum time to process redemptions or limits on redemption fees?
Q10	Should issuers be able to hold reserves across more than one registered bank? Are there other ways of holding reserves that should be permitted? Please give reasons for your view.
Q11	Do you agree with the proposed ongoing requirement to publish a monthly confirmation of reserves? If you disagree with the frequency or content, please let us know why.
Q12	Who should be permitted to carry out the annual independent verification, and to what standard? How soon after the verification date should the results be published?
Q13	Do you agree with the proposed consequence of non-compliance? Would it cause practical difficulties for issuers, holders or platforms?
Q14	Are any additional conditions required if the designation is made? For example, should issuers be required to be registered on the Financial Service Providers Register, belong to a dispute resolution scheme (if offering to retail holders), be subject to pre-launch and/or ongoing capital reserve requirements, or give holders minimum information about key terms?
Q15	Are there risks for retail holders that the proposed product features and requirements do not address? If so, what additional conditions should apply where stablecoins are issued to retail holders?
Impact and other options
Q16	Please explain the impact of the proposed designation and its conditions on the following stakeholders: • Stablecoin issuers and prospective issuers • Stablecoin holders and users • Digital asset exchanges and other platforms • Registered banks Where appropriate, please provide details of the costs and any benefits.
Q17	Do you agree with our assessment of the other options we have considered? Are there additional options we should consider?
Other
Q18	Do you have any other comments?