Public Policy – Global DCA

Public Policy

Global DCA Response – CFTC Seeks Public Comment on FTX request for Amended DCO Registration Order

GDCA writes to highlight the significant public policy benefits that could result from the approval of FTX’s proposal to amend its DCO registration order to permit it to offer non-intermediated clearing of crypto derivatives directly for participants. We believe that approving FTX’s request would signal U.S. global leadership in regulating the digital assets industry, would bring conduct that is currently happening offshore and in unregulated exchanges onshore and into the regulatory ambit, and would lead to broader market access and inclusion, among other benefits. (more…)


Global DCA Response – Response to OECD Crypto-Assets Reporting Framework and Amendments to the Common Reporting Standard

Through this response to the OECD Crypto Asset Reporting Framework (CARF), the Global DCA presented the following arguments: The Need for Secure Sharing of Data by Reporting Crypto-Asset Service Providers The Need to Support Decentralized Identity The Opportunity to Explore and Support Decentralized Tax The proposal then goes into provision of various recommendations noting that the Global DCA stands ready to collaborate with the OECD and its members to implement recommendations provided utilizing the Global DCA's broad member support to achieve tax reporting compliance while taking advantage of modern technologies to ensure vision of the right tax at the right time is realized. Please CLICK below to read the full response! CLICK HERE for the Full Response


Global DCA Response – US SEC Proposed Rule “Amendments to Exchange Act Rule 3b-16 Regarding Definition of an “Exchange”

Through this response to the US SEC "Global DCA Response - US SEC Proposed Rule "Amendments to Exchange Act Rule 3b-16 Regarding Definition of an "Exchange", the Global DCA presented the following arguments... (more…)


Global DCA Applauds ESMA Efforts to Support Distributed Ledger Technology (DLT) in European Financial Markets

Through this response, the Global DCA applauded the European Union's efforts to enable and support the application of Distributed Ledger Technology (DLT) to financial markets. We believe that DLT has the potential to significantly impact innovation and competition in financial markets. The European Securities and Markets Authority (ESMA) is absolutely correct in recognizing the potential that DLT has to improve securities settlements. In many ways, settlements illustrate a perfect use case for DLT and highlight the many benefits that may accrue to the European securities markets, financial sector, and economy. (more…)


Global DCA Welcomes Executive Order Drawing Attention to the Importance of Digital Assets

The Global Digital Asset and Cryptocurrency Association (Global DCA) is pleased that the Biden-Harris Administration has drawn needed attention to the importance of a stable, consistent, and workable regulatory framework with today's Executive Order on digital assets. We appreciate the Administration's acknowledgment of the benefits that digital assets can provide for everyone, including market participants and those outside the financial system like the unbanked and underbanked. As the Administration carries out the provisions of the Order, we are hopeful that all due care will be taken to ensure that the United States can maintain its position at the head of innovation in this critical new industry, while protecting consumers and the economy.  (more…)


Global DCA Welcomes Congressman Gottheimer’s “Stablecoin Innovation & Protection Act 2022”

The Global Digital Asset & Cryptocurrency Association welcomes and fully supports the Stablecoin Innovation and Protection Act of 2022 proposed by Congressman Gottheimer. By establishing a regulatory framework for a “qualified stable coin” and a “qualified stable coin issuer,” the proposed legislation fosters responsible innovation while establishing a foundation for public trust and consumer protection for private stable coin offerings. (more…)


Global DCA Recommends “FinCEN should use this moment as an opportunity to re-imagine the BSA/AML framework in light of new and emerging technologies”

On Monday February 14th, the Global Digital Asset & Cryptocurrency Association welcomed the opportunity to respond to FinCEN’s request for information to solicit comment on ways to streamline, modernize, and update the anti-money laundering and countering the financing of terrorism (AML/CFT) regime of the United States. The Global DCA applauded FinCEN’s purpose in requesting this feedback from the industry and recommended that FinCEN should use this moment as an opportunity to re-imagine the BSA/AML framework in light of new and emerging technologies. (more…)


Global DCA Request to US SEC for Additional Response Time – Amendments to Exchange Act Rule 3b-16 Regarding the Definition of “Exchange”

“Given the brevity of time provided for response (30 days) as well as the importance of this issue, we are deeply concerned that the public comments on the Proposed Rule will lack the number, depth and detail necessary for a fair evaluation of the Proposed Rule. Additionally, such a brief timeline hampers smaller and mid-size firms even more as they lack the critical resources to be able to review and determine the impact on their businesses necessary to respond in any meaningful way. Furthermore, we worry that a rush to judgment would negatively impact the overall effectiveness of a final rule and create unintended consequences damaging to the interests of the United States.” – Global DCA. Read Response Letter  


Global DCA Comment Letter to FASB on Treatment of Digital Assets under US GAAP

“Under the conceptual framework for financial reporting, the fundamental quantitative characteristics that make accounting information useful are relevance and faithful representation.  Accounting information is relevant if it can make a difference in a decision.  Faithful representation exists when there is an agreement between accounting information and the economic events that the accounting information purports to represent. It is difficult to conclude that the current accounting standards for digital assets fundamentally meet the objective of relevance and faithful representation for this asset class. Fair value accounting through profit and loss supports the accounting conceptual framework because digital assets are sensitive to market risk and experience market volatility.  Fair value accounting is also more relevant, provides more useful information for readers and enhances comparability across entities and industries.” – Global DCA.   Click to Read Response Letter


Global DCA Comment Letter to Bank for International Settlement on “Prudential Treatment of Cryptoasset Exposures”

“The Committee notes that for cryptoassets that confer direct claims on a pool of traditional assets held in a bankruptcy remote vehicle, a banking institution could set the credit risk exposure of bankruptcy remote assets of the redeemer to zero only if an institution has obtained a legal opinion for all laws relevant to involved parties, including the redeemer, the special purpose vehicle (SPV) and custodian, affirming that relevant courts would recognize underlying assets held in a bankruptcy remote manner as those of the cryptoasset holder. It is difficult to see how a banking institution would be able to meet that burden. It may be more constructive if the Committee were to consider proposing alternative suggestions, that could potentially offer a different standard for credit risk exposure of cryptoassets conferring direct claims on traditional assets held in a bankruptcy remote vehicle.” – Global DCA. Read Response Letter