Letters and Testimonies

Letters to Congress

Title Recipient Date
Sen. Josh Hawley 09/20/23
House Financial Services Committee 09/19/23
House Financial Services Committee 07/19/23
House, Senate Leaders 07/14/23
House, Senate 07/11/23
House Financial Services Committee 06/13/23
Senate, House leaders 06/09/23
House Financial Services Committee 05/05/23
House Financial Services Committee 04/19/23
Rep. Tom Emmer 03/08/23
Senate, House 11/17/22
House, Senate 10/11/22
Senate 10/04/22
House 09/27/22
House 09/21/22
Senate 08/31/22
House Financial Services Committee 07/22/22
Senate Judiciary Committee 05/04/22
Senate Judiciary Committee 05/02/22
Sens. Cruz, Braun, Grassley 04/04/22
Rep. Tom Emmer 04/04/22
Congress 07/27/21
116th Congress 10/15/20
U.S. House Task Force on Financial Technology 09/29/20

Letters to Regulators

Title Recipient Date
Basel Committee on Banking Supervision 03/28/24
Federal Reserve, Justice Department, Treasury Department 03/22/24
BIS Committee on Payments and Market Infrastructures 02/28/24
Letter to Regulators 01/30/24
FinCEN 01/23/24
Federal Reserve 11/27/23
IRS 11/13/23
Federal Reserve 10/20/23
IOSCO 10/18/23
White House, Treasury Department 10/12/23


Title Committee Presenter Date
House Subcommittee on Digital Assets, Financial Technology and Inclusion Written Statement 09/13/23
Senate Banking Committee Written Statement 02/13/23
Senate Banking Committee Written Statement 07/28/22
House Financial Services Committee Written statement 05/25/22
Senate Banking Hearing 02/15/22
House Financial Services Committee Written statement 02/08/22
Senate Banking Committee Written Statement 12/14/21
House Financial Services Committee Written statement 12/07/21
HSFC 09/29/20

Payments News

ICBA supports Basel Committee work on crypto disclosure framework

Jan. 31, 2024

ICBA expressed support for the Basel Committee on Banking Supervision’s work to draft a regulatory framework for disclosing cryptoasset exposures in banking entities’ financial statements.

Background: Under the Basel Committee’s consultative document, banks would use a standardized set of tables and narratives to disclose their crypto activities with associated capital and liquidity requirements and accounting classifications. Banks also would need to disclose the sources of information used in their assessments of crypto exposures in the populated data sets.

ICBA Comments: In a comment letter to the Basel Committee, ICBA said:

  • The consultation document is a good starting point for policy discussions on integrating crypto exposures into audited financial statements and regulatory capital ratios.

  • Crypto adoption poses new challenges and risks for banks, which the Basel Committee has successfully outlined in its first iteration of bank disclosures.

  • The Basel Committee should study concerns about crypto adoption and work with prudential regulators to ensure the risks are appropriately captured in bank disclosures.

  • ICBA expects this framework will need to evolve as the creation of financial instruments with crypto-like attributes gains traction over time.

Regulatory Proposals: The International Organization of Securities Commissions last fall finalized separate recommended policies to govern digital assets markets, which would generally apply global standards for securities regulation to the crypto markets. In comments to IOSCO, ICBA said the policy recommendations are prudent steps to safeguard the financial system against the risks posed by crypto assets and reinforced its view that cryptoassets are likely securities and should be subject to oversight from market regulators.

DeFi Recommendations: IOSCO has also finalized ICBA-supported recommendations calling for more consistent regulatory frameworks and oversight of decentralized finance across its member jurisdictions. In a comment letter, ICBA said IOSCO’s recommendations will help identify and manage key risks, ensure clear and comprehensive disclosures, and foster cross-border cooperation.

More: Recent Main Street Matters posts from ICBA Senior Vice President of Digital Assets and Innovation Policy Brian Laverdure cover the latest crypto collapses, the evolving regulatory environment for digital assets, and the policy debate over treating cryptoassets as securities or commodities.