Public Policy – Global DCA

The Global DCA Responds: White House Office of Science and Technology Policy Request for Information

The Global Digital Asset & Cryptocurrency Association (“GDCA”) welcomes the opportunity to comment on the US Federal Government’s National Digital Assets Research and Development Agenda. We are pleased to see the White House taking note of the transformative power of Distributed Ledger Technologies (DLT) and digital assets, which are revolutionizing the way we interact with each other and with businesses. This recognition demonstrates a forward-thinking approach to the rapidly evolving digital landscape and a commitment to leveraging cutting-edge technologies to drive innovation, promote transparency, enable secure financial inclusive opportunities, and enhance economic growth. Please click below to read the full response! CLICK HERE for the Full Response

Global Digital Asset and Cryptocurrency Association Organizes Steering Committee To Highlight Core Principles for Self-Regulation of Digital Assets

The Global Digital Asset and Cryptocurrency Association, the preeminent self-regulatory association for the digital asset and cryptocurrency industry, has organized a Steering Committee to elaborate on Core Principles for the self-regulation of customer-facing digital asset businesses. The Global DCA is calling on the industry to adopt such principles to address the causes of recent crypto business failures and to restore the industry’s tarnished credibility. The Global DCA Core Principles Steering Committee announces that the following regulatory and industry leaders have agreed to serve in the public interest as members of the Steering Committee: J. Christopher Giancarlo, Senior Counsel and Co-headof the Digital Works Practice, Willkie Farr & Gallagher / Former Chairman of the U.S. Commodity Futures Trading Commission (CFTC) Maggie Sklar, Partner, Davis Wright Tremaine / Former Senior Policy Advisor and the Director of International Engagement, Financial Markets Group, at the Federal Reserve Bank of Chicago / Former Senior Counsel at the Commodity Futures Trading Commission / Chairwoman of the Global DCA Public Policy & Regulatory Committee Renata Szkoda, Chief Financial Officer, INX / Chairwoman Global DCA Dawn Stump, Former Commissioner, U.S. Commodity Futures Trading Commission (CFTC) Carla Carriveau, Strategic Advisor/Director for crypto, fintech, and regtech startups, Former Senior Counsel and Executive Staff to Chair Mary Jo White, U.S. Securities and Exchange Commission Jamila Piracci, Founder, Roos Innovations / Former program lead overseeing the National Futures Association (NFA) regulatory program for swap dealers under the Dodd-Frank Act (2011 to 2019) / Former Attorney, Federal Reserve Bank of New York Amit Sharma, Founder & CEO, FinClusive / Former Head...

Global DCA’s Response to Request for Consultation on FSB’s Proposed Framework for the International Regulation of Crypto-Asset Activities

The Global Digital Asset & Cryptocurrency Association welcomes the opportunity to comment on the Financial Stability Board’s proposed framework for the international regulation of crypto-asset activities. GDCA applauds the process undertaken by the FSB to solicit public engagement on this important topic, and welcomes the opportunity to be part of the ongoing dialogue. When the FSB published the framework on October 11, 2022, it cited market events in the earlier part of the year that had exposed “a number of structural vulnerabilities” in crypto-asset markets and related businesses. Indeed, events like the collapse of the Terra/Luna project, the fall of Three Arrows Capital, and other events highlighted the need for significant standards setting, professionalization, regulation, and reform across the digital asset space. In light of this recent turmoil, where does GDCA believe the industry should go from here? Please click below to read the full response. CLICK HERE for the Full Response

An Open Letter to the Digital Assets Industry From the Members of the Global DCA

Crypto Association Calls for Urgent Industry Action - MarketScale From May 7th through November 11th, we have watched with dismay and horror as firms, once thought of as digital asset pioneers and leaders, have descended into catastrophic collapse. Luna, BlockFi, Celsius, Voyager, Three Arrows, FTX. In their wake, millions of customers are left with worthless claims. Many have had their savings wiped out. Still viable businesses are left teetering. More layoffs are announced daily. Those of us still standing, who believe in the potential of digital assets and have been playing by the rules, are angry at the recklessness, the ignorance and the greed that led to these collapses. No doubt all of us in the industry are processing these events and are devastated. The Global DCA believes that this dark moment presents an enormous opportunity for firms to come together and agree on a certain set of fundamental core principles. Principles that establish business practices that at their core seek to avoid, or at least mitigate, the occurrence of business failures that impact customers and the financial market at large. Interested firms can get in touch with us via emailing info@global-dca.org Please click below to read the full response. CLICK HERE for the Full Response

Down Range from Terra Luna: Stablecoin Strength Remains Unabated

Following the TerraUSD (UST) collapse and related events, the Global Digital Asset and Cryptocurrency Association (Global DCA) in collaboration with Lisa Weingarten Richards and Maggie Sklar from Davis Wright Tremaine (DWT) published the report “Beyond Terra: An Assessment of Stablecoin Benefits and Policy” (“Beyond Terra”). The report received positive support from many companies, thought leaders, and policymakers. It was also selected as a featured paper for this year’s DC Fintech Week, which showcases cutting-edge thought leadership and research from fintech academics, innovators, and others. On the other hand, the report was also subject to criticism from stablecoin skeptics, and may make points that are not in line with the stablecoin sections in the Financial Stability Oversight Council’s (FSOC) recent report: “Digital Asset Financial Stability Risks and Regulation.” This paper is a response to the critiques of the original publication, addresses some of the stablecoin rhetoric we find problematic in the FSOC report, and brings our information about true stablecoins up to date. Please click below to read the full response. CLICK HERE for the Full Response

Defining Global DCA and Self-Regulation

Click the video above to watch Global DCA's SRO Framework Roundtable (I) Design by 360 hre Click the video above to watch Global DCA's SRO Framework Roundtable (II) which includes group Q&A and full discussion. To enhance consumer and investor protection and facilitate innovation and industry development, Global DCA has launched an SRO Framework Project which will further explore and refine the organization’s nature and advancement of self-regulation. This exhaustive research, industry dialogue, and broader consultation is a necessary component of building governance institutions as governance institutions must not only reflect financial sector realities, but the broader economic, political, and social context of a given jurisdiction. Please click below to learn more. CLICK HERE TO LEARN MORE CLICK HERE TO DOWNLOAD THE POWERPOINT

Global DCA Response to Executive Order 14067 – The Benefits of Digital Asset Development

The Global Digital Asset & Cryptocurrency Association (“GDCA”) welcomes the opportunity to comment on Executive Order 14067 (the “EO”) that examines ways to ensure responsible development of the digital asset industry.1 GDCA applauds the process undertaken by the Treasury to solicit public engagement on this important topic, and welcomes the opportunity to be part of the ongoing dialogue. Given the breadth of the topics covered in the request for comment, GDCA will focus primarily on the role the Treasury Department can play in guiding the modernization of AML regulations. Please click below to read the full response. CLICK HERE for the Full Response

Beyond Terra – An Assessment of Stablecoin Benefits and Policy

The collapse of the Terra/Luna blockchain (now known as Terra Classic) is a watershed moment for the digital assets industry and warrants level-headed reflection about the future of “stablecoin” products. Given the uptick in negative sentiment, this paper dispels harmful myths about the many promising varieties of stablecoins while acknowledging the specific weaknesses of the Terra/Luna protocol and its related UST “algorithmic” stablecoin. To respond to increased scrutiny around stablecoins in the wake of UST’s collapse, we recommend policies such as Self-Regulatory Organizations (SROs), Model Risk Management (MRM) discipline, and Sarbanes-Oxley-style certification for those stablecoins secured with high-quality reserve assets. We believe that this will improve information availability and transparency and therefore reduce, if not completely eliminate, the fear of any “run“ or “contagion“ on stablecoin assets. Please click below to read the full response. CLICK HERE for the Full Response

Global DCA Response – SEC Release: Further Definition of “As a Part of a Regular Business” in the Definition of Dealer and Government Securities Dealer

Global DCA writes to comment upon the Proposing Release because of its significance to the digital asset industry and the public. In the Proposing Release, the Securities and Exchange Commission (the “Commission”) proposes to redefine the term “dealer” in Exchange Act Section 3(a)(5) by the addition of proposed new Exchange Act Rule 3a5-4. The main focus of our letter is on the application of the expanded definition of “dealer” to entities that trade digital assets that are within the meaning of the term “securities.” In our view, the application of the dealer registration requirement to such entities is unworkable, and the Commission has completely underestimated the costs of such registration. In fact, the Commission has ignored the reality that its own conduct has made dealer registration impossible for entities that trade digital assets. While we will focus on the implications of mandatory registration for traders in digital assets, we observe, as a starting matter, that we believe that the Commission’s proposed expansion of the term “dealer” is inconsistent with the historical understanding of the term as used in the statute. (more…)

Global DCA Response – Response to “Money and Payments: The U.S. Dollar in the Age of Digital Transformation”

Global DCA writes to highlight our significant views and considerations about certain key aspects of the CBDC proposal given its possible influence on the digital asset industry, financial markets, and the general public. The GDCA welcomes the new exploration and public discussion of a CBDC by the Board. The GDCA strongly supports the Board’s continued study and exploration of CBDCs. We think that a successful implementation of a U.S. CBDC could have a huge consequence on the various aspects of our society, from strengthening the Fed’s ability to implement policy, to increasing access to financial services, to speeding and modernizing financial transactions. In the long term, a U.S. CBDC, or appropriate support of private digital currency development, is essential to maintaining U.S. dollar dominance and to preserving America’s role on the global stage. (more…)