Developing a Framework on Competitiveness of Digital Asset Technologies

Published on:
July 5, 2022
Submitted to:
The Department of Commerce
Submitted by:
SIFMA

Summary

SIFMA provided comments to The Department of Commerce on Developing a Framework on Competitiveness of Digital Asset Technologies.

Excerpt

Diane Farrell

Deputy Under Secretary for International Trade

International Trade Administration

Department of Congress

1401 Constitution Ave. NW

Washington, DC 20230

Re: Developing a Framework on Competitiveness of Digital Asset Technologies

Dear Ms. Farrell,

The Securities and Financial Markets Association appreciates the opportunity to respond to the Department of Commerce’s Request for Comment (“RFC”) “Developing a Framework on Competitiveness of Digital Asset Technologies.”1 SIFMA and its members support the development of safe, regulated, digital asset markets, and are encouraged by the work underway as directed by the Executive Order 14067 of March 9, 2022, “Ensuring Responsible Development of Digital Assets” (hereafter “Executive Order”).2 This effort is a valuable step to understand the policy and regulatory frameworks necessary so that the United States can maintain a leadership role in responsible digital assets innovation, and more generally ensure that it retains the same leadership role in digital asset capital markets as it has in the “traditional” capital markets space.

In its RFC, the Department of Commerce outlined an insightful range of questions on the development of the digital assets sector in the U.S. and its competitive position. In our response, SIFMA will focus on four broad themes in these questions: 1) the competitiveness of the U.S. digital assets sector; 2) the comparison with “traditional’ financial services, in particular what “traditional” financial services can offer digital asset markets; 3) the role of Central Bank Digital Currencies (“CBDCs”) and key considerations around a potential U.S. CBDC; and 4) issues around interoperability and standards as digital asset markets develop.

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1 “Developing a Framework on Competitiveness of Digital Asset Technologies,” A Notice by the International Trade Administration on 05/19/2022 https://www.federalregister.gov/documents/2022/05/19/2022-10731/developing-a-framework-on-competitiveness-of-digital-asset-technologies

2 “Ensuring Responsible Development of Digital Assets,” A Presidential Document by the Executive Office of the President on 03/14/2022, available at https://www.federalregister.gov/documents/2022/03/14/2022-05471/ensuring-responsible-development-of-digital-assets

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