FSB全球金融稳定委员会-Addressing-the-regulatory-supervisory-and-oversight-challenges-raised-by-global-stablecoin-arrangements_-Consultative-document_67页_674kb

Summary of the FSB Consultative Document: Addressing the Regulatory, Supervisory and Oversight Challenges Raised by Global Stablecoin Arrangements

Core Content

The Financial Stability Board (FSB) has issued a consultative document to examine the regulatory, supervisory, and oversight challenges posed by "global stablecoin" (GSC) arrangements. The document is part of the G20 mandate to assess and address the risks associated with GSCs, particularly from the perspective of emerging market and developing economies (EMDEs). It outlines key characteristics of GSCs, potential risks to financial stability, existing regulatory approaches, and high-level recommendations for a coordinated international response.

Main Viewpoints

1. Definition and Characteristics of Global Stablecoins

• A stablecoin is a type of crypto-asset or digital asset that aims to maintain a stable value relative to a specified asset or basket of assets.
• GSCs are distinguished by:
  • Stabilisation mechanism: Either asset-linked (backed by real or financial assets) or algorithmic (adjusting supply based on demand).
  • Combination of multiple functions and activities: Including issuance, redemption, transfer, and user interaction.
  • Potential reach and adoption across multiple jurisdictions: Which may lead to systemic importance and financial stability risks.

2. Risks and Vulnerabilities

• Financial stability risks:
  • Systemic risks due to the potential for large-scale adoption.
  • Liquidity and credit risks from stabilisation and redemption mechanisms.
  • Operational and cybersecurity risks from the underlying infrastructure.
• Consumer and investor protection risks:
  • Potential lack of legal clarity and redemption rights.
  • Risks from inadequate reserve management and governance.
• Cross-border risks:
  • GSCs may substitute for domestic currencies, especially in EMDEs with volatile currencies.
  • Risks may span multiple regulatory domains, including banking, payments, and securities.

3. Existing Regulatory and Oversight Approaches

• Many jurisdictions have existing frameworks that apply to stablecoin arrangements, but these are often incomplete or inconsistent.
• EMDEs typically have less comprehensive regulatory coverage.
• International standards such as those from BCBS, FATF, CPMI, and IOSCO are relevant to GSCs, though not all are currently fully applicable.

4. Cross-Border Challenges

• GSCs may operate across borders, creating complexities in regulatory coordination.
• Information sharing and cooperation are essential to address cross-border risks.
• The "same business, same risk, same rules" principle is recommended to ensure consistent regulation across jurisdictions and sectors.

Key Recommendations

The FSB proposes 10 high-level recommendations to address the challenges posed by GSCs:

1. Regulatory Powers and Resources: Authorities should have the necessary powers, tools, and resources to regulate, supervise, and oversee GSCs.
2. Functional Regulation: Regulatory requirements should be applied based on the functions and risks of GSCs.
3. Cross-Border Coordination: Authorities should cooperate and coordinate both domestically and internationally to ensure comprehensive regulation.
4. Governance Framework: GSC arrangements should have a clear governance structure with defined accountability.
5. Risk Management: Robust risk management frameworks should be in place, especially regarding reserve management, cybersecurity, and AML/CFT.
6. Data Protection: GSCs should have robust systems for safeguarding and managing data.
7. Recovery and Resolution Plans: Appropriate recovery and resolution plans should be developed.
8. Transparency: Users and stakeholders should be provided with comprehensive and transparent information about the GSC arrangement.
9. Legal Clarity: Legal clarity should be provided regarding redemption rights and the process for redemption.
10. Compliance with Local Regulations: GSCs should meet all applicable regulatory requirements in any jurisdiction before operating.

Key Issues to Address

• Regulatory clarity and domestic framework gaps need to be addressed to ensure effective oversight.
• Emerging stabilisation mechanisms (including algorithmic and hybrid models) should be considered for their implications on risk analysis.
• Cross-border cooperation and information sharing are critical to managing the risks of GSCs.
• Flexibility and proportionality in regulation are necessary to balance innovation and stability.
• Adaptability to future developments is important to ensure that the regulatory approach remains relevant as GSCs evolve.

Scope and Limitations

• The document focuses on privately-issued GSCs primarily used for retail purposes, though some recommendations may apply to wholesale stablecoins and other crypto-assets.
• It does not address issues such as data privacy, competition, taxation, monetary policy, and central bank digital currencies (CBDCs).
• The FSB invites comments by 15 July 2020, with a final report expected in October 2020.

Conclusion

The FSB document underscores the importance of international coordination and robust regulatory frameworks to address the risks associated with GSCs. It highlights the need for comprehensive, flexible, and proportionate regulation that supports financial stability, market integrity, and consumer protection, while also enabling technological innovation. The recommendations aim to ensure that GSCs are subject to consistent oversight and that their systemic risks are managed effectively.