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The Securities and Exchange Commission (SEC) website published a document on March 13, titled ‘Comprehensive Proposal: XRP as a Strategic Financial Asset for the U.S.,’ which immediately sparked interest and speculation. The five-page document outlines how XRP could become a strategic tool in America’s financial arsenal, while also proposing roles for several other cryptocurrencies.
The document begins by assuming that government-level adoption of XRP could release up to 30% of the U.S.’s $5 trillion share of the global Nostro accounts, amounting to $1.5 trillion, and provide $7.5 billion in annual savings on transaction fees. It also acknowledges Bitcoin (BTC) as the strategic reserve asset, proposing that the savings from the U.S. Nostro accounts be directed towards BTC acquisition. The document suggests that the potential purchase could amount to 25 million Bitcoins, assuming an average purchase price of $60,000. However, it does not address the fact that such an amount would be approximately 20% greater than the total BTC supply or that such buying activity would cause significant price fluctuations.
The proposal suggests that the SEC declare XRP a payment network instead of a security and that the Department of Justice (DoJ) lift the bank ban in sections two, five, and six. It explains that a forced settlement ensuring the status could be imposed if there is no other way forward. The document justifies the forcing of adoption by the anticipated economic benefit of the program. However, it does not address the fact that XRP already benefits from regulatory clarity and that the SEC, in its latest appeal, does not contest the ruling that the token is not a security.
The document details standard and accelerated implementation programs, one assuming a 12 to 24-month process and the other a 6 to 12-month framework. It offers some hints into how each step could be executed but does not provide a comprehensive analysis of the execution. For example, ‘full-scale financial integration’ is accompanied by a comment stating ‘Federal Reserve & Office of the Comptroller of the Currency mandates.’
The seventh segment of the document seeks to clarify the confusion arising from President Donald Trump’s statements about a strategic cryptocurrency reserve. It proposes a set of specific roles for specific digital assets. Under the framework, Bitcoin would be the reserve asset, XRP would be used for state-level transactions, and Solana (SOL) would have a significant purpose involving ‘high-speed blockchain applications, such as real-time government databases, secure voting mechanisms, and digital identity management.’ Cardano (ADA) was also included as ‘best suited for academic credentialing, smart contracts for government services, and secure infrastructure management.’ Solana and Cardano should be integrated into U.S. digital infrastructure but not included in the reserve strategy. Instead, they enhance efficiency and security for state applications, while XRP remains the key asset for financial transactions.
The final segment of the document, titled ‘next steps & final recommendations,’ summarizes or repeats earlier parts of the document. The choice is interesting as it bolsters the document’s appearance as the result of a speculative conversation with an artificial intelligence (AI) platform. Other pointers include the overall
, filled with tables and subheadings, but, given the way more recent OpenAI models communicate, the unexpectedly high number of checkmarks as signifiers of bullet points. Despite some circumstantial evidence, it is not known whether and to what extent AI may have been used in writing the five-page ‘Comprehensive Proposal.’The document’s author, Maximilian Staudinger, appears obscure despite being known by name. It is noteworthy that anyone can submit a comment or a proposal to the SEC, and such files are frequently found on the regulator’s website. Online records of individuals with the name exist but are mostly confined to LinkedIn profiles of people in Germany and Austria, with some other socials pointing to Canada. The only interesting result is that an X account of the same name replied on March 3 to a Peter Schiff post explaining that the economist understands the logic behind a Bitcoin reserve but not behind an XRP reserve. Though brief and vague, the reply is somewhat reminiscent of some of the points raised in the ‘comprehensive proposal,’ as it states, for example, that ‘XRP as a national reserve enables fast, low-cost transactions, global acceptance & independence from central banks.’

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