Global DCA Response to US FDIC "Proposed Guidelines for Evaluating Account and Services Requests"
Many of GDCA’s members are seeking to build innovative companies at the intersection of traditional finance and the cryptocurrency and digital assets industry (the “Digital Assets Industry”). Firms in the Digital Assets Industry need access to master accounts (“Accounts”) and Federal Reserve Financial Services (“Services”) in order to break down barriers to growth and better serve their customers. GDCA welcomes the fact that the Board is proposing to formally recognize that nontraditional financial institutions, like many in our Industry, can be eligible for Accounts and Services.
The Proposed Guidelines are a step towards more clarity, transparency, and consistency, which the GDCA believes will foster growth and innovation in the Industry. Firms in the Digital Assets Industry fully embrace fit-for-purpose regulation and recognize that reasonable regulation will be a necessary part of the process of the Digital Assets Industry’s integration into the broader financial system, and the broader United States and world economies. However, if adopted, the Proposed Guidelines would unnecessarily stymie innovation, provide an unfair advantage to incumbents, and slow down the integration of fintechs and innovative firms in the Digital Assets Industry into the traditional (and aging) US payments system. Any final guidelines adopted by the Board can and should provide ready access to innovative financial institutions without increasing risk to the financial system or undermining the Board’s policy goals. Most significantly, the Board should take this opportunity to consider a tiered approach to access that would permit newer firms with fewer resources to gain access to certain services concomitant with the level of risk they pose.
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