Ladies and Gentlemen:
The Bank Policy Institute (“BPI”) and The Clearing House Association L.L.C. (“TCH”)[1] appreciate
this opportunity to comment on two documents issued by the Financial Stability Board (“FSB”): (i) the consultative document on the regulation, supervision, and oversight of crypto-asset activities and markets (“Crypto-Asset Consultative Document”)[2] and (ii) the consultative report on the review of the FSB’s high-level recommendations for the regulation, supervision, and oversight of global stablecoin arrangements (“GSC Consultative Report”).[3] BPI and TCH commend the FSB for its work on these issues and fully support the FSB’s goal of developing uniform international principles applicable to crypto-asset activities and global stablecoin arrangements.[4]
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[1]See Appendix A for information about BPI and TCH.
[2] FINANCIAL STABILITY BOARD, REGULATION, SUPERVISION AND OVERSIGHT OF CRYPTO-ASSET ACTIVITIES AND MARKETS: CONSULTATIVE DOCUMENT (Oct. 11, 2022) (hereinafter CRYPTO-ASSET CONSULTATIVE DOCUMENT).
[3] FINANCIAL STABILITY BOARD, REVIEW OF THE FSB HIGH-LEVEL RECOMMENDATIONS OF THE REGULATION, SUPERVISION AND OVERSIGHT OF “GLOBAL STABLECOIN” ARRANGEMENTS: CONSULTATIVE REPORT (Oct. 11, 2022) (hereinafter GSC CONSULTATIVE REPORT).
[4] The FSB defines a crypto asset as “[a] digital asset (issued by the private sector) that depends primarily on cryptography and distributed ledger or similar technology. Crypto-assets include, but are not limited to, a cryptoasset that is classified as a payment instrument in a jurisdiction and a crypto-asset that is classified as a security in a jurisdiction.” See CRYPTO-ASSET CONSULTATIVE DOCUMENT, supra note 2, at 71. In a 2020 consultative document, the FSB defined a digital asset as “[a] digital representation of value which can be used for payment or investment purposes. This does not include digital representations of fiat currencies. FINANCIAL STABILITY BOARD, ADDRESSING THE REGULATORY, SUPERVISORY AND OVERSIGHT CHALLENGES RAISED BY ”GLOBAL STABLECOIN” ARRANGEMENTS: CONSULTATIVE REPORT 4 (Apr. 14, 2020). As neither definition includes central bank digital currency (“CBDC”), BPI and TCH assume that CBDC is outside the scope of these consultations and have not included comments related to CBDCs.
