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3/19/2020

Remarks by Acting Assistant Secretary for International Markets Mitchell A. Silk at the Fourth Annual Conference on Fintech and Digital I…

Remarks by Acting Assistant Secretary for International Markets
Mitchell A. Silk at the Fourth Annual Conference on Fintech and
Digital Innovation
March 3, 2020

As prepared for delivery:
March 3, 2020
Brussels, Belgium
The Importance of Financial Innovation to Economic Growth and Financial Stability
Thank you to Nick and Afore for putting together today’s impressive program. It is so great to see
many old friends and also to spend time with many of you who are quickly becoming new ones.
The mere fact that such a distinguished group is gathered to discuss financial innovation is a
testament to the dramatic nature of the technological innovations sweeping across the financial
sector today.
I’d like to share some thinking on the issues of speed and velocity of financial innovation in the
context of balancing market growth and stability. In particular, here are few thoughts on how
the policy maker and regulator may, will and should consider and respond to cutting edge
developments in disruptive financial innovation to support a number of policy goals: healthy
growth; appropriate access; market stability and security; and consumer protection.

FINANCIAL INNOVATION IN HISTORICAL CONTEXT
To project into the future and as context to the present, let’s take a brief visit to the past. In
order to do that, I’d like to tell you about our crown jewel at the Main Treasury Building in
Washington, D.C., the Cash Room. Let me tell you a little about its aesthetics, the operations and
function, and safeguards of the Cash Room, as it was originally designed, in order to highlight
the impact of innovation on financial services and some of the challenges that confront us all.
A small bit of trivia is that the room was unveiled 151 years ago tomorrow for the inauguration
of President Ulysses S. Grant in 1869. The event was so crowded that it took guests two hours to
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Remarks by Acting Assistant Secretary for International Markets Mitchell A. Silk at the Fourth Annual Conference on Fintech and Digital I…

retrieve their coats.
No expense was spared in creating this very grand and majestic room. It was meant to be a
roofed version of an all-marble traditional Italian palazzo bank to provide confidence in the
strength of the U.S. Dollar. At the time it was completed it was believed to be one of the most
expensive rooms in the world.
The Cash Room is of truly grand dimensions – it is 22m long and 10m wide, with vaulted ceilings
that rise over 10m – and extraordinary design and architecture.
The Cash Room served a number of functions.
As its name indicates, a key function of the Cash Room was to store currency and to provide the
public with check cashing services for transactions with the federal government.
To give you a sense of scale, in 1974, tellers at the Cash Room cashed almost eight million local
checks for the public. That’s over 30,000 checks per business day.
The Cash Room also served as a ‘Bankers bank’, to sell coin and currency to local banks. Again,
as a measure of scale, Treasury processed over 650 million dollars in coins and 41 million dollars
in currency for local banks in 1974. That’s over 3 billion dollars in today’s terms – or over 100
million kilograms (or roughly 250 million pounds) in coins. For those who associate with wildlife,
think of the weight of over 25 thousand African Elephants or over 1,200 Blue Whales. That’s a lot
of blubber.
As to security, the Cash Room’s money was stored in one of four working vaults in the Main
Treasury Building. The Cash Room’s vault was no ordinary vault. The vault had a truly ingenious
security design that you can see in our building that was patented by Isaiah Rogers, then
Supervising Architect of the Treasury, in 1864. The vault’s unique burglar proof lining consisted
of two layers of cast iron balls between plates of wrought iron and hardened steel. The balls
rotated freely when in contact with a drill preventing penetration and breaching of the vault.
That was from the 1860s through the 1970s. With the advent of electronic banking, we closed
the Cash Room in 1976 for operational purposes. We realized that local banks o ered the same
services at lower unit cost, and that the Federal Reserve could provide the same currency
services. Closing the Cash Room saved the Treasury almost two million dollars per year in
operating expenditures.
The aesthetics of this grand room remain the same. However, the financial operations and
security features have been rendered completely obsolete as a result of financial innovation. As
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Remarks by Acting Assistant Secretary for International Markets Mitchell A. Silk at the Fourth Annual Conference on Fintech and Digital I…

such, the Cash Room and its vault now serve as a meeting space and a wonderful place to
provide historically significant tours.

FINANCIAL INNOVATION TODAY
Against that backdrop, let me focus on the present day. Fortunately, we at the Treasury
Department have learned to be more forward thinking and forward leaning when it comes to
innovation.
President Trump and Secretary Mnuchin have been leaders in this area, recognizing that actively
cultivating technology expertise in finance ministries and other authorities is a critical means to
execute on our core mandates.
Financial innovation has been at the heart of the administration’s regulatory reform e orts,
which have focused on appropriately calibrating regulation to better enable growth, while
maintaining high-quality regulatory standards. For example, Treasury’s fourth and final report in
response to President Trump’s Executive Order 13772 on financial regulation, titled “Nonbank
Financials, Fintech, and Innovation,” provided a roadmap to a streamlined regulatory
environment that will foster growth and stability in the context of financial innovation.
However, in the international sphere, I worry about a di erent dynamic. It sometimes seems
that the late Paul Volcker’s maxim that the “the ATM has been the only useful innovation in
banking for the past 20 years,” still guides some authorities’ approach. A er all, we were told in
the lead up to the crisis that innovative new financial instruments like collateralized debt
obligations and credit default swaps would help mitigate excessive risk-taking.
It is undeniable that today, international financial authorities face a range of new challenges on
the horizon as a result of financial innovation. Much of this challenge is driven by the precise
element that makes financial innovation so compelling – its speed and velocity – and all the
consequential consumer benefits as well as attending regulatory challenges.
Here are but a few:

So-called “stablecoins” that have the potential to become widely adopted in multiple
jurisdictions have raised questions regarding their potential implications for both financial
institutions and central banks in the financial system.
Artificial intelligence and machine learning pose novel questions about how we should
regulate financial decisions made exclusively by machines.
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Remarks by Acting Assistant Secretary for International Markets Mitchell A. Silk at the Fourth Annual Conference on Fintech and Digital I…

Banks, already facing increased regulatory pressure and compressed margins, face
competition from both startups and large technology companies.
Our view is that it would be a grave mistake to remain in a defensive crouch. As authorities, we
should confidently rise to these challenges and embrace the opportunities they represent.

The concerns raised by global stablecoins also has sparked a long-overdue discussion on
improving cross-border payments.
The adoption of artificial intelligence for supervisory purposes could potentially free up
previously occupied human capital and ease regulatory burdens.
Banks are able to leverage new forms of partnerships with both fintech and BigTech firms to
expand their reach and access new markets.
The increased speed and velocity, complexity, and cross-border nature of financial innovation
raises legitimate questions about whether a new forward-leaning mindset is needed for policy
makers, regulators and supervisors.
New business models provide avenues to o er services to the underbanked or unbanked, both
domestically and abroad. The unbundling of financial services allows for specialization,
allowing smaller fintech firms to focus on one specific and customized product or o ering.
Firms may o er new financial tools to save consumers money and increase e iciency, driving
additional capital formation and productivity gains.
Continued international engagement will be of critical importance going forward, especially as
it pertains to financial innovation. Given the space is so dynamic, it will require continued and
thorough cooperation to usher in policy recommendations that achieve responsible innovation
while safeguarding global financial stability.
Treasury’s O ice of International A airs is leading the Administration’s engagement across the
international financial ecosystem.
In the multilateral context, we cooperate with our friends in Europe and throughout the globe
on a number of e orts with our international counterparts, many of whom are in this room.
In the Financial Stability Board’s (FSB) Standing Committee on Assessment of Vulnerabilities, we
are actively examining the changes to the financial system as a result of the entrance of
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Remarks by Acting Assistant Secretary for International Markets Mitchell A. Silk at the Fourth Annual Conference on Fintech and Digital I…

technology companies and new forms of third party service suppliers, and whether these
changes in market structure could present new vulnerabilities to financial stability.
We have stepped up our engagement on data connectivity. Unnecessary restraints on financial
institutions’ ability to move data across borders are a significant threat to both productivity
growth and financial stability, and we are responding to the challenges posed by countries who
are erecting harmful barriers like data localization requirements.
We are using our G7 presidency in increase focus on the issue. We recently formed a new G7
experts group on cross-border data flows to coordinate the G7 response to this emerging
challenge.
We have also been leading on the topic de jour in today’s financial world: payment systems and
digital assets.
Undersecretary McIntosh is Co-Chairing the FSB’s Regulatory Issues of Stablecoins (RIS)
working group that is leading the response to global stablecoins.
My colleagues in the O ice of Terrorism and Financial Intelligence are leading at the
Financial Action Task Force (FATF), the global standard setter for combatting money
laundering and the financing and terrorism and proliferation, as it implements new virtual
asset standards agreed under the U.S. presidency of the FATF last year.
We have also recently stood up a new G7 digital payments expert group under the U.S.’s G7
presidency.
We have also stepped up our bilateral engagement with key jurisdictions around the globe.
Financial innovation and its implications are a central topic in our standing bilateral
dialogues, including with Japan, India, the EU, and the UK.
We have stood up a standalone partnership on financial innovation with the UK.
And just last week, I hosted a full day program with our Israeli counterparts and key
members of the Israeli private sector to deepen our cooperation and further e orts to
calibrate the regulatory environment to support growth and stability.

These are examples of how we are rising to the challenge globally. But these challenges will
continue to evolve at a breathtaking pace. As stakeholders in the international financial system,
we need to consider how respond.
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Remarks by Acting Assistant Secretary for International Markets Mitchell A. Silk at the Fourth Annual Conference on Fintech and Digital I…

Let’s return to the issue of the speed and velocity of financial innovation. Do our goals of growth
and stability require us to slow down to speed up? Or, do they require us to speed up to slow
down? Or neither?
Most certainly, financial regulation could benefit by speeding up to meet the pace of technology
and innovation. At the same time, innovators – particularly those developing novel and
disruptive technologies or business models – could benefit from a measured pace to allow a
considered policy and regulatory approach.
We at Treasury look forward to continuing to work with our European and international
counterparts to further our mission of healthy growth, appropriate access, market stability and
security, and consumer protection, all in the context of a rapidly changing financial landscape.
Thank you.
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