The Chamber of Digital Commerce submitted comments to the Financial Stability Board (FSB) addressing the regulatory, supervisory, and oversight challenges raised by the vast network of crypto-asset activities and global stablecoin arrangements worldwide. 

Digital currency and crypto service providers have the capability to bring tremendous improvements to our national and international financial systems by enabling frictionless, instantaneous transferability of value. It is imperative that lawmakers contemplate a regulatory scheme that can appropriately mitigate risk, but any regulatory scheme needs to be principles-based. Much of the recent turbulence in the crypto markets can be addressed with measured regulatory oversight.

The Chamber’s response focuses on four overarching principles (below) that should be a theme in any framework to regulate and supervise crypto-asset activities moving forward. Any new or introduced regulation must be workable to exist effectively in all relevant jurisdictions.

  1. Balance Risks of Crypto-assets with their Potential for Innovation. Each type of risk associated with the various crypto-asset activities should consider the potential benefits.
  2. Promote Cross-Border Cooperation while Maintaining Cybersecurity and Data Privacy. Access to data is necessary to facilitate cross-border cooperation, but breadth of access must be weighed against the need for security and user privacy.
  3. Create Comprehensive Risk Management Guidance that is Proportional to Market Size. A company’s market size is critically important as businesses often make decisions on what they believe to be a best practice but have limited standards for comparison.
  4. Require Disclosures that Sufficiently Protect Consumers and Promote Transparency. Disclosure requirements should be principles-based and reflective of the risks and information relevant to the particular market participants’ activities and size.

As with any regulatory framework the devil will always be in the details, but the FSB should embrace a principles-based framework and with a deep appreciation for the acceptance and use of digital assets and blockchain technology.

The FSB posed fifteen specific questions. Read the Chamber’s entire 22 page response here.