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Wyoming Stable Token Commission outlines vendor selection, test tokens and rules; flags reserve and taxonomy questions
Summary
The Wyoming Stable Token Commission reported vendor selections, live test tokens on multiple testnets and a near‑term rule timetable; staff highlighted a statutory 2% reserve buffer and raised taxonomy and permitted‑investment questions the legislature may wish to address.
Jackson — The Wyoming Stable Token Commission briefed the Select Committee on its procurement, rulemaking and pilot testing work and urged the legislature to consider technical and statutory clarifications before a full public launch.
Anthony Apollo, executive director of the commission, told the committee the commission has completed a multi‑stage procurement process and engaged key vendors: Layer 0 Labs as token‑issuance partner and Inca Digital for on‑chain open‑source intelligence; other negotiations were ongoing and expected to be completed in the coming days. The commission said it has launched unreserved test Wyoming stable tokens on multiple testnets and is registering Wyoming individuals and domiciled entities for alpha/pilot testing.
The commission reported rulemaking progress: reserves‑management rules had been posted to the Secretary of State’s website and a 45‑day public comment period is beginning; a separate token‑treatment rule that will specify mint/redemption, interdiction triggers and other on‑chain behavior is in draft and expected to be circulated to commissioners before the end of May.
Statutory and operational issues: Apollo told members that Wyoming statute requires a minimum over‑collateralization buffer (the commission cited “2%” in statute) to back token supply. Commission staff said that if the token’s market cap grows rapidly and treasury returns decline, the commission could face a perpetual catch‑up challenge where interest income lags supply growth and the 2% target is difficult to meet. He described possible options: (1) maintain conservative permitted investments and accept slower growth, (2) add a secondary, more diversified permitted‑investment basket or (3) adopt an investment‑fund wrapper (for example, a 2a‑7‑style regulated structure) to increase near‑term yield while maintaining strict maturity and liquidity limits. Apollo said the State Treasurer’s Office has been engaged to explore options.
The commission also asked the legislature to consider updating digital‑asset taxonomy and statutory definitions. Commissioners and staff said current statutory terminology (the earlier “virtual currency” phrasing in Wyoming law) can conflate distinct asset classes and complicate policy, and they recommended a more modern, modular taxonomy so the legislature and agencies can clearly treat fiat‑backed stable tokens, commodity‑backed tokens, NFTs and other instruments differently.
Other operational notes: the commission described technical procedures to handle unsolicited on‑chain donations (the commission’s vendors proposed immediate segregation and a compliance review before any disposition), said it has hired a risk and compliance lead (Deborah Brooks), a CFO (Joseph Saldana) and a chief information security officer (Keith Lawhorn), and said it intends to use licensed service providers (LSPs) for initial distribution to retail users while the commission scales. Apollo said the commission aims to proceed aggressively with testing and, subject to test outcomes and vendor integrations, is targeting a summer launch cadence.
Questions from committee members included whether the state’s stable token could be mistaken for a central bank digital currency (CBDC). Apollo and Commissioner Flavia Nava Navez said Wyoming’s token is fiat‑backed and state‑issued under state law, and that the commission intends to be explicit that the token is not a CBDC; committee members asked the administration to consider proactive outreach to federal offices to avoid mischaracterization.
What’s next: the commission will continue vendor negotiations, document testing outcomes, receive public comment on posted rules and work with the legislature on possible statutory clarifications (taxonomy, permitted investments, interdiction standards and the commission’s 2% reserve requirement). Commissioner David Pope asked the committee to review one statutory paragraph (Wyo. Stat. § 40‑31‑106(b)) to ensure auditors and the commission interpret the 101%/102% reserve language consistently.
