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9/23/2022

Remarks by Under Secretary for Domestic Finance Nellie Liang at the Brookings Institution | U.S. Department of the Tr…

U.S. DEPARTMENT OF THE TREASURY
Remarks by Under Secretary for Domestic Finance Nellie Liang
at the Brookings Institution
September 23, 2022

INT RODUCT ION
Thank you for inviting me to join you today to talk about recent reports led by Treasury as
part of President Bidenʼs Executive Order on Ensuring Responsible Development in Digital
Assets. My remarks today will focus primarily on how digital assets could alter the future
money and payments system in the US, and recommendations in the report to prepare for
that. But I will first take a few minutes to talk about the here-and-now of digital assets—how
they are currently being used and their e ects on consumers, investors, and businesses. And
next month, the Financial Stability Oversight Council will issue a report on the financial
stability risks of digital assets and regulatory gaps.

CRYPTO-ASSETS
For the report titled “Crypto-assets: Implications for Consumers, Investors, and Businesses,”
the charge was to focus specifically on current use cases for crypto assets, and especially use
by and e ects on more vulnerable communities. A main finding of the report is that the most
prevalent current uses of crypto-assets are for trading, lending, and borrowing. Use of
crypto-assets to deliver other types of financial services, like payments at lower cost, higher
speed, and without intermediaries, has not materialized yet.
The report finds significant areas of concern. There are frequent instances of operational
failures, market manipulation, frauds, the s, and scams. Consumers and investors are
exposed to improper conduct in crypto-assets for a variety of reasons, including a lack of
transparency, non-compliance with existing regulations, as well as that crypto-assets have
novel and rapidly developing applications. In addition, while the data for populations
vulnerable to disparate impacts remains limited, available evidence suggests that cryptoasset products may present heightened risks to these groups, and little evidence of financial
inclusion benefits.
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Based on these findings, our first recommendation is for agencies to continue to aggressively
pursue their enforcement e orts focused on the crypto-asset sector. A second
recommendation is for agencies to clarify their existing authorities to ensure they are applied
appropriately to crypto-assets, and for regulators to work cooperatively so they can be more
comprehensive and increase compliance with existing rules. These recommendations
recognize that agencies -- including the CFPB, SEC, CFTC, and DOJ – have been hard at work
to address this unlawful activity and to protect consumers and investors. Agencies have
expanded and prioritized resources – the SEC, for example, has brought more than 80 cases.
The recommendations also reflect a principle that financial services, whether provided by
crypto technology or traditional financial firms, should be subject to the same rules if they
pose the same risks. That is, rules should be technology neutral.
The report also recommends that agencies work together, through the Financial Literacy and
Education Commission, to improve the quality of information about crypto-assets for
consumers, investors, and businesses. The goal is to make trustworthy and consumer-friendly
materials accessible and inclusive.

F UT URE OF MONEY AND PAY MENTS
Iʼll now turn to the report on the future of money and payment systems. Here we focus on
digital assets used for money and payments, as well as instant payment systems, and make a
set of recommendations to put us on a path to a more e icient, innovative, and inclusive
money and payments system, and to reinforce U.S. global economic and financial leadership.
The current money and payment system has many strengths. The system has supported over
a century of U.S. growth, processes an enormous volume of transactions, and supports
privacy, civil rights, and other democratic values. But some parts of the payment system are
expensive and carry high fees, and other parts are slow. It also is not as inclusive as it should
be: The percentage of the United States that is unbanked is higher than in all other G-7
countries.
Looking forward, recent innovations in digital assets and other technologies could have farreaching implications for money and payments. These innovations include a central bank
digital currency (CBDC), retail instant payment systems, and stablecoins. The report builds on
the work of the Presidentʼs Working Group on Financial Markets, which recommended
legislation for consistent and comprehensive oversight of stablecoins. The report does not

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Remarks by Under Secretary for Domestic Finance Nellie Liang at the Brookings Institution | U.S. Department of the Tr…

make any new recommendations regarding stablecoins, but instead considers implications of
stablecoins for the payment system.
Iʼll now discuss the money and payment systems and the recommendations reviewed in the
report.

CB DC
Iʼll turn first to CBDC. A CBDC is a digital form of a countryʼs sovereign currency. It is a liability
of the central bank. A U.S. CBDC would serve as legal tender, be convertible one-for-one into
paper currency (Federal Reserve notes) or reserve balances (deposits at the Fed). It would
clear and settle with finality and nearly instantly.
The reportʼs first recommendation is for the U.S. to advance work on a possible CBDC should
one be determined to be in the national interest. There are potential benefits that could
a ect a decision to adopt a U.S. CBDC, such as preserving the uniformity of the currency, or
providing a base for further innovation. There are many important design choices that would
require additional consideration. For example, a retail CBDC would be broadly available to the
public, while a wholesale CBDC would be limited to banks and other financial institutions. This
choice could a ect private credit availability in normal times and in periods of stress. There
also is a need for further research and development on the technology to support a U.S.
CBDC, which could take years.
For the U.S. to build capacity to adopt a CBDC, even as deliberations continue about whether
one is in the national interest, the report suggests work in a number of areas. In addition to
supporting continued evaluation and periodic updates to the public by the Federal Reserve,
Treasury will lead an inter-agency working group to support the Fedʼs e orts and advance
further work on a possible U.S. CBDC. The CBDC Working Group will consider the implications
of CBDC in areas such as financial inclusion, national security, and privacy. Leadership from
the Federal Reserve, the White House, and the Treasury Department will meet regularly to
discuss the progress of the CBDC Working Group, and to share updates on CDBC and other
payments innovations.

INSTANT PAYMENTS
Iʼll turn now to instant payments. Retail instant payment systems transfer funds nearly
instantly, as opposed to the multi-day settlement period that occur on some legacy systems.
In the U.S., examples include the Clearing Houseʼs RTP Network, launched in 2017, and the
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FedNow Service, which the Fed plans to launch in 2023. Global experience suggests that
instant payments can contribute to making the payment system, as a whole, more
competitive, e icient, and inclusive. Yet frictions may limit the extent to which the potential
benefits of instant payment systems are realized. Consumers, businesses, and financial
institutions may be slow to adjust their habits and procedures to new technologies. In
addition, instant payment systems are generally accessible only to depository institutions.
To maximize the benefits from instant payments, the report suggests e orts in three areas.
First, the U.S. government should continue outreach e orts around instant payments, with a
focus on inclusion of underserved communities. Second, the U.S. government should promote
development and use of innovative technologies that allow consumers to more readily access
instant payment systems. And third, in settings where appropriate, U.S. government
agencies, which send and receive millions of payments a day, should consider and support the
use of instant payment systems.

F EDERAL F RAMEW ORK
The reportʼs third recommendation is to consider establishing a federal regulatory framework
for nonbank providers. This recommendation recognizes that nonbanks are increasingly
providing payment services. These newer entrants may contribute to higher enhanced
competition, inclusion, and innovation. Today, oversight of nonbank payment providers is
generally at the state level, varies significantly, and may not address certain risks in a
consistent and comprehensive manner. A federal framework could provide a common floor
for minimum financial resource requirements and other standards that may exist at the state
level. It also would complement existing federal AML/CFT obligations and consumer
protection requirements that apply to nonbank payment providers.
A federal framework for payments regulation could work in conjunction with a U.S. CBDC or
with instant payment systems. It could provide oversight of firms that a potential U.S. CBDC
system may rely on for a range of financial services. It also could lay out a path for nonbank
payment providers to participate directly in instant payment systems.

CROSS-B ORDER
The reportʼs final recommendation prioritizes work to develop a faster, cheaper, and more
transparent international payment system, while considering potential risks of greater
integration of cross-border payment systems. Indeed, private sector payment innovations
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have been driven in part by ine iciencies in the current cross-border payment systems. Crossborder payments can take multiple days to clear, and may carry high fees.
The U.S. has a strong national interest in supporting global standards for cross-border
payment systems that reflect U.S. values, including privacy and human rights; are consistent
with AML/CFT considerations; and protect U.S. national security.

CONCLUSION
To conclude, as laid out in the Executive Order, new technologies when developed responsibly
can lead to significant e iciencies and further innovation. The future of money and payments
report sets out a set of recommendations with a deliberate path forward to determine if a
CBDC is in the national interest and to support the development and adoption of other
innovations. This path will achieve the potential benefits of innovations while mitigating risks
to consumers and economic growth and stability.
Fact Sheet: Treasury Report on Crypto-Assets: Implications for Consumers, Investors,
and Businesses

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