The Clearing House Association, L.L.C. (TCH) submitted comments in response to the Department of Commerce’s International Trade Administration’s (ITA) notice and request for comment on “Developing a Framework on Competitiveness of Digital Asset Technologies.” TCH, in its comments, observed that privately-issued digital assets, and private token-based money that is not issued by anyone, have grown tremendously over the past decade and pose a number of significant risks. With respect to privately-issued digital assets and private token-based money that is not issued by anyone, TCH commented that: (i) banks, which are subject to comprehensive supervision and regulation frameworks, should be no less able to engage in digital-asset-related activities than nonbanks; (ii) federal regulatory clarity is imperative; and (iii) a comprehensive federal prudential framework applying standards to digital assets that are equivalent to those that apply to depository financial institutions when engaged in functionally similar activities is essential. With respect to a U.S central bank digital currency (CBDC), TCH noted that the risks associated with the possible issuance of a CBDC in the U.S. outweigh its potential benefits. Additionally, TCH noted that the policy goals that have thus far been articulated in support of a CBDC would be best addressed through less risky, more efficient, and more economic alternatives that are either readily available in the market today or are under development through public and private initiatives.
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