Financial Associations Recommend Action to Remove Barriers to Digital Assets Innovation

Washington, D.C. —  A coalition of financial services trade associations urged the President’s Working Group on Digital Asset Markets to support efforts to remove barriers to financial institutions engaging in digital asset activities. The associations include the Bank Policy Institute, American Bankers Association, American Fintech Council, Americas Focus Committee of the Association of Global Custodians, Financial Services Forum, Securities Industry and Financial Markets Association and The Clearing House Association.

In a joint letter, the associations acknowledge the meaningful progress the Federal Reserve, the FDIC and the OCC have made in rescinding policies and guidance that have hindered banks’ ability to engage in digital asset activities. The associations recommend additional steps that the banking agencies can take to advance bank innovation further.

“The U.S. will not be able to achieve a leadership position in digital assets and financial technology under the status quo,” the letter states. “Banks are an essential component of the financial and payments systems and are governed by a comprehensive regulatory framework carefully crafted to mitigate the risks inherent to financial activities. It is therefore critical that the federal banking agencies take further steps to facilitate banks’ ability to engage in digital asset activities.”

The associations made three key recommendations in the letter:

  1.  Create consistent rules across agencies. The federal banking agencies should coordinate to issue joint rules and guidance when possible. If joint guidance isn’t possible, the agencies should at least align their policies to avoid conflicting requirements.
  2. Regulate the activity, not the technology. The agencies should affirm that banks may engage in permissible banking activities regardless of the technology used. A tokenized asset is no different from the traditional form of that asset; therefore, the regulatory framework should be technology-neutral.
  3. Set clear risk-management expectations. Rather than requiring individual institutions to obtain permission from their regulator prior to engaging in digital asset activities, the agencies should issue uniform expectations for how institutions should manage the risks of those activities, including anti-money laundering, capital and liquidity risks.

The associations’ recommendations are aligned with the objectives outlined in the President’s Executive Order on Digital Asset Markets and build on their February 20, 2025, letter to the PWG. While the banking agencies have addressed many of the recommendations, the associations continue to urge the Federal Reserve to revise its Policy Statement on Section 9(13) of the Federal Reserve Act and to rescind SR 23-7, “Creation of a Novel Activities Supervision Program.”

To access a copy of the letter, please click here.

Media Contacts:

Austin Anton
Bank Policy Institute
[email protected]

Sarah Grano
American Bankers Association
[email protected]

American Fintech Council
[email protected]

Walter Palmer
Americas Focus Committee of the Association of Global Custodians
[email protected]

Laura Peavey
Financial Services Forum
[email protected]

Katrina Cavalli
Securities Industry and Financial Markets Association
[email protected]

Greg MacSweeney
The Clearing House Association
[email protected]

About Bank Policy Institute

The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud and other information security issues.

About American Bankers Association

The American Bankers Association is the voice of the nation’s $24.1 trillion banking industry, which is composed of small, regional and large banks that together employ approximately 2.1 million people, safeguard $19.2 trillion in deposits and extend $12.7 trillion in loans.

American Fintech Council

A standards-based organization, AFC is the premier trade association representing the largest financial technology (Fintech) companies and innovative banks. Our mission is to promote a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.

About Americas Focus Committee of the Association of Global Custodians

Established in 1996, the Association of Global Custodians is a group of 12 financial institutions that provide securities safekeeping services and asset-servicing functions to primarily institutional cross-border investors worldwide. As a non-partisan advocacy organization, the Association represents members’ common interests on regulatory and market structure matters through comment letters, white papers and interaction with legislative and regulatory authorities and financial industry organizations. The member banks are competitors, and the Association does not involve itself in member commercial activities or take positions concerning how members should conduct their custody and related businesses. The Americas Focus Committee operates as an overarching full committee to address all Association matters involving regulatory/market structure issues arising in North or Latin America.

About Financial Services Forum

The Financial Services Forum is an economic policy and advocacy organization whose members are the eight largest and most diversified financial institutions headquartered in the United States. Forum member institutions are a leading source of lending and investment in the United States and serve millions of consumers, businesses, investors, and communities throughout the country. The Forum promotes policies that support savings and investment, financial inclusion, deep and liquid capital markets, a competitive global marketplace, and a sound financial system.

About Securities Industry and Financial Markets Association

SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development.  SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).

About The Clearing House Association

The Clearing House Association L.L.C., the country’s oldest banking trade association, is a nonpartisan organization that provides informed advocacy and thought leadership on critical payments-related issues. Its sister company, The Clearing House Payments Company L.L.C., owns and operates core payments system infrastructure in the United States, clearing and settling more than $2 trillion each business day.