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3/23/2022

Remarks by Under Secretary for Domestic Finance Nellie Liang to the National Association for Business Economics | U.…

Remarks by Under Secretary for Domestic Finance Nellie Liang
to the National Association for Business Economics
March 22, 2022

As prepared for delivery
Thank you to Julia and NABE for inviting me to participate in this panel. I will talk today about
two topics. First, I will review the recent executive order (EO) on digital assets and Treasuryʼs
work on the future of money and payments. Second, I will describe the Presidentʼs Working
Group (PWG) analysis of stablecoins and our recommendations to reduce risks while allowing
for development and innovation.
Earlier this month, President Biden signed an executive order on digital assets. It calls for a
coordinated and comprehensive approach to the responsible development of digital assets as
a new means to provide financial services, including money and payments. The primary
objective of the EO is to address the risks and harness the potential benefits of digital assets,
which will reinforce American economic competitiveness and global financial leadership.
Over the coming months, Treasury will partner with colleagues across the government to
produce a series of reports and concrete recommendations. Treasury has significant
responsibilities in at least four areas. First, the future of money and payment systems, with a
discussion of central bank digital currency (CBDC); second, financial stability risks and
regulatory gaps posed by various types of digital assets; third, their use for illicit finance and
associated national security risks; and fourth, international engagement to support global
principles and standards for digital assets and CBDC.
Our work on the EO will be guided by some shared core values for financial services. We want
broader access to safe and a ordable financial services, which can foster equitable economic
growth and financial inclusion, while protecting consumers, investors and businesses from
significant risks of digital assets.
We want to maintain a resilient financial system. Regulatory policy for new financial products
may need to evolve, but should follow “same risk, same regulation,” in the sense that
regulations should be based on risks of the activity rather than the technology itself.
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Remarks by Under Secretary for Domestic Finance Nellie Liang to the National Association for Business Economics | U.…

We also want to reduce illicit finance risks and safeguard national security from misuse of
digital assets. And, for technology, we want to encourage responsible innovations that
reinforce US leadership and are consistent with democratic values.
Let me turn to the report on the future of money and payments.
Treasury will write this report and will consult with others. There are a focused set of topics
to address, including new forms of money, both private and sovereign, new ways to transfer
money, and implications for the economy, financial system, financial inclusion, and national
security. Some specific questions are the consequences of possible design choices for a
CBDC; how private digital assets would interact with CBDC; and the e ects of advances in
CBDC in other jurisdictions. The EO emphasizes an urgent need for research and development
on the potential design and deployment options of a CBDC so that the US is prepared to
move forward if it is determined that it would be in the national interest.
As we start, we recognize that new forms of money are gaining popularity in part because
existing forms of money and payments have some weaknesses. For example, costs and fees
for bank accounts with low balances can be high. In addition, cross-border payments,
including remittances, are ine icient and slow. . Reflecting these and other factors, some
households may not have adequate access to bank accounts and reliable payment systems.
We also recognize that there are developments that could address some of these issues. For
example, FedNow aims to be a 24/7 payment system that will be low cost to users and widely
available. Because FedNow relies on the banking system, there already are safeguards for
consumers and businesses. In addition, bank-based money usually has deposit insurance and
banks are generally eligible to obtain access to the lender of last resort. These two backstops
help to ensure that bank money is not runnable. Another example are stablecoins if wellregulated. With appropriate guardrails, they could support e icient provision of payment
services.
Our work will complement other important e orts, including the Federal Reserveʼs recent
paper on CBDC. In that paper, the Fed emphasized that any CBDC should ensure privacy for its
users, have an intermediated model, be transferable, and prevent illicit finance. The Fedʼs
paper does not make a determination of whether a CBDC would be in the national interest,
but raises a wide range of issues and asks for public feedback.
The EO calls on the Fed to continue studying CBDC, and in particular how it might a ect the
ability to e ectively implement monetary policy, recognizing that sovereign money is at the
core of a well-functioning financial system, macroeconomic stabilization policies, and
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3/23/2022

Remarks by Under Secretary for Domestic Finance Nellie Liang to the National Association for Business Economics | U.…

economic growth. In addition, the EO calls on the O ice of Science and Technology Policy and
the Chief Technology O icer of the United States, in consultation with the Fed, Treasury, and
others, to issue a report on the technological infrastructure, capacity, and expertise that
would be necessary to support a CBDC system should one be proposed.
In addition to the new work on the future of money, Iʼd like to talk about ongoing work on
stablecoins.
Stablecoins play a significant role in the emerging set of digital assets, activities, and services.
The distinguishing feature of stablecoins is that they are designed to maintain a stable value
relative to a reference asset – o en, the U.S. dollar. Stablecoins have grown rapidly, from a
market capitalization of roughly $5 billion at the start of 2020 to approximately $175 billion
today. The PWG, plus the OCC and the FDIC, issued a report in November 2021 that focused
on stablecoins because the o er of a stable value means they have the potential to be used
widely used by households and businesses to make payments and purchases. Many
companies are exploring ways to increase their use for these purposes.
The PWG report highlighted some significant “prudential risks” associated with stablecoins
for payments. First, run risk -- a scenario in which loss of confidence that a stablecoin will be
stable could trigger a wave of redemptions, which could have spillover e ects for the broader
financial system. Second, payment risk -- including operational issues that could interfere
with the ability of users to actually store and transfer them to make payments. And third,
concerns related to concentration of economic power – for example, if a stablecoin provider
gained market power and harmed competition and consumers.
The PWG report found significant gaps in authorities that would address these prudential
risks. Some of the largest stablecoin issuers operate with limited regulatory oversight, and
there are significant questions about whether they are adequately backed. Even where a
stablecoin issuer is subject to oversight, supervisors may not have su icient visibility into the
broader operations, such as custodial wallet providers, that support the use of the stablecoin,
which may be distributed across multiple entities. Current requirements under state money
transmitter or securities laws were not designed to address the risks of runs, payment
system, or concentration of economic power for a payment instrument based on new
distributed ledger technology.
To fill this regulatory gap, the PWG report recommended legislation to ensure a consistent
and comprehensive framework that is proportionate to the prudential risks posed.
Importantly, such legislation would complement existing authorities with respect to market
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Remarks by Under Secretary for Domestic Finance Nellie Liang to the National Association for Business Economics | U.…

integrity, investor and consumer protection, and illicit finance. The report recommended
specifically: to limit issuance of stablecoins to insured depository institutions; to give
supervisors of stablecoin issuers visibility into the broader stablecoin arrangement, and
authority to set risk-management standards for critical activities related to use of stablecoins
for payment; and to consider other protections – such as data privacy or interoperability -- to
reduce concerns related to concentration of economic power.
In developing the recommendation for stablecoin issuers to be insured depository
institutions, the PWG report relied upon the flexibility that the banking agencies would have
to adjust for di erences between stablecoin issuers and traditional commercial banks, and to
new products and structures that may emerge over time.
Digital assets and the associated technology have introduced new channels for the delivery
of financial services. These may be part of creating a more e icient inclusive financial system
alongside other e orts. There are, however, some known risks that should be addressed. For
example, it is important to keep moving on our e orts on stablecoins-- they are growing and
regulators need to establish guardrails to prevent significant systemic risks from emerging.
We will appeal to our shared goals of protecting consumers, financial stability, and American
leadership as we work together to ensure the strength of the financial system.
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