Former Commodity Futures Trading Commission Acting Chair Caroline Pham argues that tokenized deposits may be better suited than stablecoins to wholesale financial markets because banks still need to net obligations rather than settle every trade independently in real time.
Pham told The Block that atomically settling a full trading day could require approximately $15 trillion in cash. The figure is her estimate, not a published regulatory calculation, but it identifies a practical constraint often missing from tokenization claims.
Conventional market infrastructure offsets obligations among participants and transfers only the residual balances. Immediate gross settlement can reduce counterparty exposure while sharply increasing liquidity requirements. Tokenizing the settlement asset does not remove that tradeoff.
Pham said stablecoins remain useful when counterparties do not know or trust one another or require delivery-versus-payment settlement. Tokenized commercial bank deposits may fit wholesale networks better because they preserve bank balance-sheet treatment and can support established liquidity and netting arrangements.
She also argued that the Commodity Exchange Act already reaches most commodities and that existing CFTC authority can support crypto rules after the Clarity Act failed. Pham is now MoonPay’s chief legal and administrative officer. Her comments do not bind the CFTC and should be read as an experienced market participant’s interpretation, not an agency decision.
TOKEN RECON ASSESSMENT
The useful intelligence is the distinction between faster ledgers and better market plumbing. Institutions do not need every obligation settled separately if that forces them to hold vastly more idle cash. The winning tokenized settlement model may therefore combine programmable assets with netting, credit and central-bank or commercial-bank money rather than replacing those functions with continuous gross settlement.
Source
The Block: Caroline Pham on CFTC authority, tokenized deposits and wholesale settlement
