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| Title | Recipient | Date |
|---|---|---|
| Comments on Basel Cryptoasset Standard Amendments | Basel Committee on Banking Supervision | 03/28/24 |
| Freedom of Information Act Request on CBDC Authority | Federal Reserve, Justice Department, Treasury Department | 03/22/24 |
| Joint Trade Statement on ISO 20022 Standards | BIS Committee on Payments and Market Infrastructures | 02/28/24 |
| Disclosure of Cryptoasset Exposures | Letter to Regulators | 01/30/24 |
| ICBA Comment Letter for FinCEN Cryptocurrency Mixer Proposal | FinCEN | 01/23/24 |
| Joint Extension Request on Fed Debit Card Interchange Price Cap | Federal Reserve | 11/27/23 |
| Comments on Proposed Tax Treatment of Digital Assets | IRS | 11/13/23 |
| Joint Trades Letter on Reg II Board Meeting | Federal Reserve | 10/20/23 |
| Response to IOSCO DeFi Policy Recommendations | IOSCO | 10/18/23 |
| Joint Letter on Mortgage Rates | White House, Treasury Department | 10/12/23 |
| Title | Committee | Presenter | Date |
|---|---|---|---|
| Statement for House Hearing on Central Bank Digital Currency Risks | House Subcommittee on Digital Assets, Financial Technology and Inclusion | Written Statement | 09/13/23 |
| Effective Regulation of Crypto Assets | Senate Banking Committee | Written Statement | 02/13/23 |
| Statement for Senate Crypto Hearing | Senate Banking Committee | Written Statement | 07/28/22 |
| Hearing Statement on Central Bank Digital Currency | House Financial Services Committee | Written statement | 05/25/22 |
| Enhanced Regulation of Digital Assets Will Promote Responsible Innovation | Senate Banking Hearing | 02/15/22 | |
| Statement for House Hearing on Stablecoins | House Financial Services Committee | Written statement | 02/08/22 |
| Statement for Senate Stablecoin Hearing | Senate Banking Committee | Written Statement | 12/14/21 |
| Statement for House Hearing on Digital Assets | House Financial Services Committee | Written statement | 12/07/21 |
| ICBA Statement for HFSC Fintech Hearing 9-29-2020 | HSFC | 09/29/20 |
May 27, 2022
Members of Congress from both parties raised concerns about the impact of a U.S. central bank digital currency on community banks after ICBA told lawmakers it opposes the digital dollar.
Congressional Concerns: During a House Financial Services Committee hearing on the benefits and risks of a CBDC, several committee members raised questions reflecting ICBA concerns about the community bank impact.
Rep. Brad Sherman (D-Calif.) raised concerns that a CBDC would reduce bank deposits, particularly among community banks, decreasing funding for home and business loans.
Rep. Andy Barr (R-Ky.) emphasized that even an intermediated CBDC system would result in deposits exiting community banks and the broader banking system.
Rep. Sean Casten (D-Ill.) questioned why a bank would have any incentive to take CBDC deposits if they are a liability of the Federal Reserve and there’s no way to lend against them.
Ranking Member Patrick McHenry (R-N.C.) questioned whether a CBDC provides any benefits that cannot be delivered by the private sector.
Arguments in Favor: Nevertheless, some policymakers indicated support for a U.S. CBDC.
Committee Chairwoman Maxine Waters (D-Calif.) said a U.S. digital dollar could provide the benefits promised by cryptocurrency without the risks posed by private issuers.
The sole witness—Federal Reserve Vice Chair Lael Brainard—similarly said the digitalization of the financial system and private-sector risks could necessitate a U.S. CBDC, touting the “intermediated” model the Fed is considering.
ICBA Statement: In its statement for the hearing, ICBA reiterated key points from its recent comment letter to the Fed that a a U.S. CBDC would:
Disintermediate community banks, obstructing their ability to take deposits and make loans.
Be costly for community banks.
Pose privacy and cybersecurity risks.
Not be an alternative to privately issued stablecoins.
Better Alternatives: ICBA’s statement also says the FedNow instant payment service is a more viable solution for payments modernization that complements increased Same Day ACH adoption and The Clearing House’s RTP service.