The Clearing House Association, L.L.C. (TCH) submitted comments in response to the Treasury Department’s notice and request for comment on “Ensuring Responsible Development of Digital Assets.”
TCH, in its letter, observed that privately-issued digital assets and private token-based cryptocurrency have grown tremendously over the past decade and pose a number of significant risks. With respect to these digital assets, TCH commented that: (i) banks, which are subject to comprehensive supervision and regulatory frameworks that help ensure their digital-asset-related activities are conducted safely and soundly and that consumers are protected, should be no less able to engage in digital-asset-related activities than nonbanks; (ii) federal regulatory clarity is imperative, particularly where digital assets will serve as a means of payment or will be held in custody by financial institutions; and (iii) a comprehensive federal prudential framework applying equivalent standards to digital assets as 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.
To read the full comment letter click here