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The Age of Public Digital Currency: A Guide To Issuance GLOBAL DIGITAL FINANCE supported by: 02 The Age of Public Digital Currency: A Guide To Issuance | October 2020 Contents Foreword 04 Authorship 05 I. Introduction 07 II. How cryptocurrencies developed 08 III. Solutions available today 11 IV. Policy considerations 12 V. Summary 18 VII. Further reading 18 04 The Age of Public Digital Currency: A Guide To Issuance | October 2020 Foreword In the past 18 months the subject of Central Bank Digital Currency has accelerated dramatically from potential research areas, to key policy agenda. Unquestionably, this has been driven by developments in Facebook-initiated Libra where the spectre of the private sector playing more of a role in medium of exchange and store of value was entirely possible. In this time weve also seen the Peoples Bank of China develop its Digital Currency Electronic Payment platform (DECP), which it is aiming to streamline and improve the connectivity between central bank payments, the commercial banking sector and big techs who play a crucial role in payments. In its recent whitepaper on CBDCs the Bank of International Settlements found that at least 48 central banks now have some active research or proof of concept in development for CBDC. Since the rise of the COVID-19 pandemic, cash circulation has dropped significantly in many economies, digital payment types have increased, and the focus on efficient, fair and transparent payments has become high profile in all areas of the economy. The subject is vast, and offers opportunities to potentially drive real policy opportunities, market efficiency and perhaps most excitingly, better outcomes for consumers around the world. There are a number of great documents and papers on this subject, however it is increasingly difficult to stay on top of it all. So, GDFs Digital Currency Working Group has pulled together this report to offer the current state overview from an industry perspective. Lawrence Wintermeyer Executive Co-Chair, Global Digital Finance Simon Taylor Co-Chair however, it wasnt until Tether was listed on Bitfinex in 2015 that the asset type gained global notoriety. By 2019, there was a proliferation of proposed stablecoin announcements, to be used both in private and public blockchain commerce, from JPMorgan, to the Libra Association, to the central bank of China. In March 2020, as the US Congress considered legislation to soften the economic recession coming from the COVID-19 pandemic, several of its members proposed legislation that featured a CBDC. This solution incorporated a digital wallet to enable all Americans, including the most vulnerable and unbanked, to receive COVID-19 federal aid directly via a “digital dollar”. 2 A cryptocurrency tends to be defined as a token or “coin” that utilizes an open blockchain to function. A digital currency may utilize an open blockchain but could also be enabled by a “closed” or proprietary blockchain. A. Analyzing stablecoins Viewing stablecoins from different angles can produce different perspectives on the primacy of their individual characteristics, which may affect policymaking. Three perspectives for consideration are backing, pricing and decentralization: “Backing” - how they are collateralized or stabilized to control volatility (e.g. collateralized or backed with fiat monies or stabilized with an algorithm). We should note that being backed and collateralized may have different legal implications with respect to investor recourse in the case of losses (e.g. whether investors have a claim to assets held in reserve). “Pricing” - the value that they reference (e.g. 1 USD, the value of 1 gram of gold, or a basket of currencies). “Decentralization” - e.g do they rest on a fully transparent public blockchain or on a permissioned, private blockchain where data privacy, participants and scaling can be managed? For more on this topic readers should consult the Global Digital Finance paper 2019. 3 3 gdf.io/wp-content/uploads/2019/10/GDF-Stablecoin-Key- Considerations.pdf 09 10 The Age of Public Digital Currency: A Guide To Issuance | October 2020 B. Stablecoin developments and use cases While stablecoins initially sprung from private endeavours to help investors hedge against the volatility of the cryptocurrency market, a CBDC dollar could be issued by the Federal Reserve and/or OCC and disseminated through the US via the existing two-tiered banking system of traditional banking institutions and intermediaries to end users. It would have to be interoperable and co-exist with current and future financial infrastructure both domestically and abroad. It should act as a catalyst for the private sector to innovate and upgrade this infrastructure. With the US dollar as an example, tokenizing or making the USD digital transforms it from an analog fiat currency to a digital currency that can be shared and tracked across borders with the greatest of ease, thus preserving the USDs status as the worlds premier reserve currency. New projects such as Hyperledgers eThaler 4 (built on Ethereum) and the Digital Dollar Project 5 continue to advance the digital USD case rapidly. There are a number of use cases that require reduced volatility to eventually have real consumer adoption: Remittance - requires reduced volatility while payments are being processed Commerce retail CBDC wallets should allow such peer-to-peer transfers as well. When it comes to larger amounts, held or transferred, sovereign governments will insist on transactions being controlled between identities that are formally checked using KYC/AML and/or other methods. E. Issuance/Governance In most countries, it would be the province of the respective central bank or treasury department to issue a CBDC or digital dollar, as it is already responsible for the issuance of paper currency. The digital dollar would be distributed through the existing banking system; however, in the U.S., new federal legislation will need to be enacted to authorize the development and use of a digital dollar. For the United States, new legislation should consider authorizing the OCC, in consultation with the Financial Stability Oversight Council (FSOC), with primary authority to issue regulations on the issuance and permitted uses of the CBDC dollar. In July 2020, the OCC formally allowed federally chartered financial institutions to maintain digital custody services for their clients, or digital wallets. This is a clear precursor to a digital dollar. It is an unlikely coincidence that Brian Brooks, the new head of the OCC, is the former CLO at Coinbase and a former active member of GDF. 14 The Age of Public Digital Currency: A Guide To Issuance | October 2020 The FSOC was formed from the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 and is statutorily mandated to create collective accountability of its 15 federal and state members for risks and response to emerging threats to U.S. financial stability. Among other things, the regulations would be expected to consider AML, privacy, cybersecurity, interoperability, custody, and identity issues. Policymakers should think seriously and thoughtfully as to who is best suited to develop and issue a digital dollar as it is a growing concern amongst public and private stakeholders alike. F. Custody A retail digital dollar may end up being in great demand due to its liquidity and zero rate lower bound. Custodial services bundled with other services may become the norm for such an asset, especially for large holdings of retail digital dollars. Retail digital dollars tend to follow one of two models: account-based or token-based. Most of the retail digital dollar proposals, such as the ones offered in the US that seek to emulate cash are exploring a token-based approach. Almost all of them call for a two-tier system. As discussed earlier, digital dollars, being an inherently digital product, requires custody through a digital organizational wallet. Self-custody for smaller amounts and for retail spending could be accomplished through a personal wallet, perhaps held and accessible via an individuals mobile phone. For a token-based model, the actual tokens would follow current regulations and are held in a separate, custodial wallet. Using a third party to maintain custody of the tokens is advisable to guard against theft or wallet hacks. Through lessons learnt from crypto-assets custody, management of private keys can be implemented to avoid loss of public digital currencies. Custody and digital asset transfers can either be based on hardware (Hardware Security Module or HSM) or software (Multi Party Computation or MPC). In the case of MPC, the private key is decentralized and managed via different nodes that hold a portion of the information required to retrieve the private key. In the case of HSM, a multi-signature process can be established to guarantee that all parties approve before a key is used to move funds. Rules must be made clear on matters such as regulatory compliance, adequate insurance, and shelter from the bankruptcy of the custodian. The custodian will need to be a well-regulated entity to prohibit unilateral moving of funds. G. Interoperability A digital dollar should be designed and implemented with interoperability through the following dimensions: Transactional Function: interoperability with the existing financial global system for payments, credit/lending, storing, protecting (insuring), and investments of financial assets. Technical: interoperability with the standardised technical standards and protocols that support payments, credit/lending, storing, protecting (insuring), and investments of financial assets. It should be tightly interoperable and programmable with other standard technologies. It should leverage and use common Cloud services, technologies and orchestration, and programming languages for policy management, automation, and easier systems management. As a Unit of Exchange/Value: interoperability and exchangeability with existing fiat currencies, CBDCs, and any other officially government regulated currencies, including other government currency backed digital currencies and stablecoins. H. Role of banks During the move towards a CBDC architecture, commercial and central banks could be involved in either a retail CBDC or wholesale CBDC, such as the Fnality project. The distinction between a retail CBDC and a wholesale CBDC has a two-fold effect on banks. First, it would determine the holder of the asset on the balance sheet. Commercial banks would be the designated holders for a wholesale CBDC, whereas central banks would take that place for a retail CBDC. Second, it would impact the designator of the assets transfer execution. In the case of a wholesale CBDC, commercial banks would continue to serve that role; however, a retail CBDC would mandate that central banks fulfil the role. In general, a CBDC would enable faster, cheaper, and more transparent payments for clients, especially for international payments with banks that lack a local banking license. A CBDC would also improve cash/ treasury management during the life cycle of client and commercial bank transactions. Moreover, a CBDC would improve solutions to working capital needs and provide a “value chain” optimization by providing programmable transactions to clients (conditional settlement, automated 15 rebates, etc.). Lastly, a CBDC would enhance credit exposure by taking some risks away via conditionalized payments (smart contract-based) and smarter collateral management (when pre-funding a transaction for instance). Even with the adoption of a pure retail CBDC, commercial banks would still be able to provide different services around the token. For example, they could provide custodial services to their end users (private key management services), as well as services centered around validation and ensuring financial transactions comply with KYC requirements. Multiple service layers could also be provided by banks through their wallets, such as “programmable money,” IOT integration, and data analysis. Moreover, banks would likely continue to play the role of a secure lending counterparty on digital assets or broker digital asset payments. Finally, specialized services such as investment management, fund management, and letters of credit can still be performed by commercial banks. When adopting a CBDC, banks will face a multitude of challenges, beginning with the heavy investment required to fund new DLT/blockchain technologies. Banks would also risk losing privileged relationships with other financial institutions (especially with the current corresponding banks system) while shifting their business strategy. Finally, central banks themselves would require heavy investment in system resilience and cyber-security. They would also need to adapt to the burden of managing a large balance sheet with financial stability risks. I. Credit Credit is an important part of the wholesale, large value payments infrastructure. Hence, we concentrate on wholesale CBDC first and the effects on credit. Daily large value interbank payments volume is 100 times the deposit balance held at the central bank. Therefore, interbank high value payment volumes will be more than 100 times any wholesale CBDC held by banks. Liquidity crunches result when there is continuous settlement. Banks rely on incoming payments to finance outgoing payments. This means periodic netting and settlement using Real Time Gross Settlement (“RTGS”). 8 Wholesale CBDC can be used in RTGS independent of the central bank, creating a decentralized infrastructure for RTGS. 8 The term real-time gross settlement (RTGS) refers to a funds transfer system that allows for the instantaneous transfer of money and/or securities. Current wholesale payment infrastructure sources of liquidity include reserve balances at the central bank, borrowing from money markets, credit extension from the central bank, and incoming transfers from other banks. Of these, the central bank credit extension can be in the form of wholesale CBDC with special programmatic restrictions. Short term lending of CBDC is also possible to satisfy ephemeral liquidity needs, resulting in the development of a repo market. If so, standing instructions to custodians from clients could result in this market taking off. Retail CBDC can also be used in credit markets. Today, there are some popular crowdfunding platforms. While holding the safest asset, it is possible for ordinary people and smaller businesses to lend retail CBDC seeking higher yield. Clearly, the higher risk of these loans requires vigilance and higher yield. Unlike cash, this can be relatively friction-free; of course, lenders risk appetite and desire for yield play an important part in this equation. J. Monetary stability The US Dollar is the reserve currency of the world economy. Its stability relative to most global currencies has given
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