According to CoinMeta, Wu said that the Federal Reserve Bank of America Institute ( BPI ) and The Clearing House Association have submitted letters of opinion to the Financial Crimes Enforcement Network ( FinCEN ) recommending that customer identification programs ( CIP ) be further extended to the secondary market for stablecoins, including digital asset custodians, exchanges, digital asset service providers ( DASP ), and some decentralized market participants. In particular, those DASP that establish account relationships with customers are required to fulfill identity verification obligations. The current proposed rules mainly cover the direct relationship between stablecoin issuers and primary market customers, and discussions are underway regarding whether to extend these requirements to the secondary market as well.