President Biden’s recent executive order on digital assets was, as the Financial Times reported, short on policy detail. There was a commitment to “reinforce US leadership in the global financial system” through means including “the responsible development of payment innovations and digital assets”.
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Crypto billionaire Sam Bankman-Fried
“I don’t think it moves the needle that much from where we were before. I think it’s more just a reflection of where the administration is than anything else,” the CEO of crypto exchange FTX told CNBC.
From Biden’s Crypto Order: Sam Bankman-Fried, Kevin O’Leary, Novogratz React.
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But there was also emphasis on studying how some form of central bank digital currency (CBDC) could work in practice, which once again has raised the question of what the point of digital dollar might be.
Christopher Waller, a member of the Board of Governors of the Federal Reserve System, said earlier this year he was sceptical that a Federal Reserve CBDC “would solve any major problem confronting the U.S. payment system”. I actually agree with the general sentiment here, but I would phrase it in a slightly different way: that there is no “burning platform” for a retail central bank digital currency in the United States. Appropriately-regulated private sector “stablecoins” could be used to satisfy the demands of the decentralised finance (“defi”) sector for money that can be algorithmically-traded for cryptographic assets.
Having said that, it is not obvious that the long-term goals of such stablecoins would be congruent with wider public policy goals around money and payments. President Biden’s order included a mention of the potential for a US digital dollar “to foster greater access to the financial system” but when it comes to financial inclusion, I have to say that it is not at all clear to me how a CBDC could deliver greater access unless there is greater access to the digital wallets in which such currency might be stored. If these wallets can only be provided by banks, and the same customer due diligence (CDD) rules will apply as for bank accounts, then
The Brookings Institute has just published an alternative proposal calling for an account-based alternative (that would undoubtedly be lower cost). They say that “while the need to address financial inclusion is great, some question whether a Fed-administered CBDC is the best way to reach retail markets”. That “some” would definitely include me.
We propose that the U.S. Treasury Department create “Treasury Accounts” as a means of improving access to financial services for many Americans. These would be digital accounts that would facilitate distribution of federal benefits and provide low cost, no-frills payment services. Treasury could create these accounts under existing statutory authority. In addition, Treasury’s substantial experience, dating back several decades, in devising benefit distribution and payment service programs for individuals can serve as the foundation for our proposal. Treasury Accounts could make it easier for those who are underserved by today’s banking system to both open and sustain an account. We propose a limit on account size and rollovers to private accounts to minimize disintermediation of bank deposits. As the public debate heats up over whether to create a U.S. central bank digital currency (CBDC), we explain why Treasury is better suited, at least in the short term, to provide retail accounts than the Federal Reserve, and why this proposal would be a faster, easier way to achieve some of the primary objectives of a CBDC.
If this is the case, then
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There are many compelling reasons to have a digital dollar. At the top of the list are much faster transaction times, easier access to money for many, and less risk of fraud. If executed smoothly, it would help ensure the U.S. dollar remains the world’s most favored currency. As the Fed wrote in January, adding an official U.S. government digital currency is “a means to expand safe payment options, not to reduce or replace them.”
But there are also serious concerns and practicalities that must be worked out. How will people access the digital dollar? Will there be government-run “digital wallets,” or will those digital wallets occur only in the private sector? The Fed has indicated it does not particularly want to become a consumer bank. Similarly, would a digital dollar use blockchain technology, like bitcoin and other e-currencies? That would help prevent fraud, but it would be a huge expansion of blockchain usage. Finally, how will the government use all of the new data it collects from digital dollar users, and what privacy protections will be in place? China offers a cautionary tale, as its government can track all transactions and seize digital yuan assets. Launching a digital currency will also be expensive, especially because of the need to ensure the system is not hacked.
From Opinion | The U.S. should not rush into a digital dollar – The Washington Post.
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But How?
The key barrier
Another potential advantage of Treasury Accounts could be in simplifying know-your-customer (KYC) screening, which often prevents or discourages unbanked persons from obtaining private accounts. Moreover, once someone is on a “do not bank” list of account screening consumer reporting services such as ChexSystems, it can be very difficult to get an account from any bank. The account opening screening for a Treasury Account could be considered largely or entirely satisfied by the eligibility criteria—that is, the fact that someone has already established eligibility for and is receiving government benefits means a further KYC process is not necessary. If so, the same standard could apply to the transfer to a private firm account if the Treasury Account maximum were reached.
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The Federal Reserve Bank of Boston (Boston Fed) and the Massachusetts Institute of Technology’s Digital Currency Initiative (MIT DCI) are collaborating on exploratory research known as Project Hamilton,
From Project Hamilton Phase 1 Executive Summary – Federal Reserve Bank of Boston.
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Despite using ideas from blockchain technology, we found that a distributed ledger operating under the jurisdiction of different actors was not needed to achieve our goals. Specifically, a distributed ledger does not match the trust assumptions in Project Hamilton’s approach, which assumes that the platform would be administered by a central actor. We found that even when run under the control of a single actor, a distributed ledger architecture has downsides. For example, it creates performance bottlenecks, and requires the central transaction processor to maintain transaction history, which one of our designs does not, resulting in significantly improved transaction throughput scalability properties.
Well, I imagine that the core of their discovery was that a blockchain is a very specific solution to the problem of forming consensus in the presence of untrusted third parties but in a Federal Reserve digital currency of any kind there would be no such parties.
CBDC design choices are more granular than commonly assumed. Currently, CBDC designs are categorized as direct, two-tier, or hybrid models, with “token” or “account” access models 1 2 7 12 15. We found these limited categorizations lacking and insufficient to surface the complexity of choices in access, intermediation, institutional roles, and data retention in CBDC design 10. For example, wallets can support both an account-balance view and a coin-specific view for the user regardless of how funds are stored in the database.
Going Offline
I have written before (eg, here in Forbes) that one of the great attractions of building a new digital cash infrastructure to implement a digital currency, instead of just laying a simple peer-to-peer protocol on top of the existing digital money infrastructure, is that it would add to diversity to the infrastructure and therefore resilience to the payment system, which is vital national infrastructure.
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DCash — the digital currency used by seven Caribbean nations — has been down for the last two weeks and it’s unclear when it will be back online, the Eastern Caribbean Central Bank said Friday.
From Caribbean Digital Currency, DCash, Remains Offline for Second Week.
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It’s not just that CBDC must work offline, but that it must work independently from he existing electronic money infrastructure.
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Many Kazakh citizens rely on traditional digital payment methods like debit cards to buy food, but without internet connections, these were rendered useless. Local media have reported long queues for ATMs and withdrawal caps because of shortages of cash.
For central banks, the situation in Kazakhstan shows both the importance and the limitations of cash. The crisis makes it clear that it will not be enough for central banks to develop an online digital currency transaction network while treating cash as the offline back-up.
From Kazakhstan unrest highlights importance of offline payment functionality – OMFIF.
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This one of the aspects of digital currency that fascinates me. Some innovative thinking will required to deliver a genuine cash alternative into mass markets and my strong suspicion is that it will depend on the use of secure, tamper-resistant hardware. Writing [here a year ago], Vipin Bharathan talked about Visa’s proposed Offline Payment System (OPS) which implement digital currency using digital signatures generated in this hardware, in the form of Trusted Executions Environments (TEEs) in mobile phones and laptops and so on. This is only one of the solutions being proposed but it illustrates the general class of most-likely implementation rather well: since these chips cannot be cloned, they provide a means to prevent the subversion of transactions even when they are device-to-device with no blockchain or database in sight.
These TEEs are chips (just the like chips on bank cards or the SIM cards inside mobile phones) that cost next to nothing.
China