Comment Text:
Re: Tokenized Collateral and Stablecoins Initiative (Press Release 9130-25)
Submitted by FreshCredit Inc
Signed by: Dan Thygesen, Chair of the Board
Date: October 1st, 2025
Introduction
FreshCredit Inc thanks the Commission for its leadership in advancing the safe and responsible integration of tokenized collateral and stablecoins into regulated financial markets. FreshCredit Inc is a Wyoming-based corporation building infrastructure for credit, identity, and payments. We have previously been invited to provide technical input in Washington, D.C., reflecting recognition of our subject matter expertise.
Position
Industry Readiness: Tokenized collateral and stablecoins are poised to become foundational to modern financial infrastructure. For this transition to succeed, systems must be auditable, interoperable, and resistant to concentration risk.
Infrastructure Commitment: Our technology provides decentralized verification across distributed nodes, enabling audit trails, interoperability, and transparency. This directly supports the Commission’s priorities around custody, valuation, and settlement.
Stablecoin Partnerships: FreshCredit Inc partners with stablecoin providers including Circle, ensuring compatibility with U.S.-licensed, widely adopted stablecoins. These integrations demonstrate both our readiness for pilot programs and our alignment with the regulatory framework contemplated by the Commission.
Technical Credibility: FreshCredit Inc holds U.S. patents filed in 2021 covering blockchain-agnostic decentralized verification systems. These patents are evidence of foresight and rigor, though our focus here is on broader principles of safety and inclusion.
FRAND Commitment: FreshCredit Inc supports licensing under Fair, Reasonable, and Non-Discriminatory (FRAND) principles for technologies deemed essential to tokenized collateral frameworks. This ensures broad market access while preserving incentives for innovation.
Recommendations to the Commission
- Encourage blockchain-agnostic frameworks to avoid vendor concentration and systemic risk.
- Promote pilot programs that integrate decentralized verification into collateral workflows.
- Mandate immutable audit trails across heterogeneous systems as a condition for recognition.
- Support FRAND licensing of essential technologies to balance innovation with fair access.
Closing
FreshCredit Inc is committed to working with regulators and industry participants to ensure tokenized collateral systems are safe, auditable, and inclusive. We welcome the opportunity to participate in Commission-led pilot programs and consultations.
Respectfully submitted,
Dan Thygesen
Chair, FreshCredit Inc
