FSB全球金融稳定委员会-Report-and-recommendations-on-regulatory-supervisory-and-oversight-of-challenges-raised-by-global-stablecoin-arrangements_-overview-of-public-consultation_8页_184kb

Summary of FSB Report on Regulatory, Supervisory and Oversight Challenges of Global Stablecoins

Core Content

The Financial Stability Board (FSB) published a consultative document in April 2020 proposing 10 high-level recommendations to address regulatory, supervisory, and oversight challenges posed by global stablecoin (GSC) arrangements. The consultation received 53 responses, with a majority of respondents supporting the document and its recommendations. Key themes included the need for a consistent and technology-agnostic regulatory approach, the importance of addressing systemic risks, and the necessity of international cooperation.

Main Views and Key Information

1. Regulatory Approach and Technology Neutrality

• Respondents generally endorsed the "same business, same risk, same rules" principle.
• They emphasized that regulatory frameworks should not be technology-specific and should evolve with market developments.
• There was a call for a holistic regulatory approach that covers financial stability, consumer protection, competition, and data privacy.

2. Definition and Classification of Stablecoins

• While the definition of stablecoins was broadly supported, some respondents suggested it could be more precise.
• There was a recognition that a common international taxonomy for stablecoins and other crypto-assets would help in consistent classification.
• The report clarified that it does not propose a specific categorization of stablecoins but references other documents that do.

3. Stabilisation Mechanisms

• Most respondents agreed with the two stabilisation mechanisms described (asset-linked and algorithm-based).
• Some highlighted the need for further clarification on the differences between these mechanisms.
• Hybrid mechanisms were acknowledged as existing, and their implications on risks were noted.

4. Functions and Activities of GSC Arrangements

• The functions and activities of GSC arrangements were well understood by respondents.
• They stressed the importance of applying existing international frameworks (e.g., BCBS, FATF, CPMI-IOSCO) to these functions.
• Decentralized and permissionless technologies were identified as posing challenges in terms of accountability and governance.

5. Differentiation of GSCs from Other Stablecoins

• GSCs were characterized as stablecoins with global reach and substantial volume.
• Characteristics in Annex 5, such as reserve size, customer base, and market share, were seen as useful in determining global status.
• Some suggested that interconnectedness with digital platforms should also be considered as a criterion.

6. Risks to Financial Stability

• Most respondents supported the analysis of financial stability risks.
• Key risks included reserve management, cybersecurity, operational resilience, and potential impacts on monetary policy and currency substitution.
• Some noted that adequate stabilisation mechanisms and risk management could mitigate these risks.

7. Regulatory Tools and Standards

• Respondents supported the application of existing international standards to GSC activities.
• They highlighted the importance of addressing operational and cybersecurity risks, including the use of ISO/IEC 27001 for information security.
• There was a call for more clarity on data privacy and digital identifiers.

8. Cross-Border Issues

• Cross-border risks were well-recognized, including regulatory arbitrage and the need for international cooperation.
• Concepts like "home/host supervisor" and "lead overseer" were well-received.
• Issues related to capital controls, AML/CFT, and currency substitution were also raised.

9. Appropriateness of Recommendations

• Most respondents agreed the recommendations were appropriate and proportionate.
• They emphasized the need for flexibility and proportionality, especially for different types of stablecoins and their functions.
• Some suggested that Recommendation 10, which requires compliance with regulatory requirements before operations, might hinder innovation and called for regulatory sandboxes.

10. Wholesale vs. Retail Stablecoins

• The recommendations were seen as generally applicable to both retail and wholesale stablecoins.
• Respondents noted that while the risks differ, the core principles should apply across both types.
• Some suggested that more detailed regulations may be needed for specific use cases, such as wholesale stablecoins on private ledgers.

11. Additional Recommendations

• No recommendations were suggested for removal.
• Some respondents called for more precision in certain recommendations, such as qualifications for issuers and custodians.
• There was a consensus on the need for further work on AML/CFT, consumer protection, data privacy, and competition.

12. Cost-Benefit Considerations

• Most respondents agreed that a proportionate regulatory approach is essential to foster innovation while protecting consumers and ensuring financial stability.
• They noted that cost-benefit analysis is challenging at this stage due to the lack of real-world examples.
• Benefits such as financial inclusion in EMDEs and improved cross-border payments were highlighted, alongside the potential risks.

Conclusion

The FSB has made amendments and clarifications to its recommendations based on feedback, including the clarification of the "same business, same risk, same rules" principle, the inclusion of more detailed criteria for identifying GSCs, and the recognition of the importance of regulatory sandboxes. The final report emphasizes the need for a flexible, comprehensive, and internationally coordinated approach to regulate GSC arrangements. It also commits to regular review of its recommendations to ensure they remain relevant and effective in the face of evolving market dynamics.