Payments

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

Testimony

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 to Basel Committee: Strengthen protections against crypto risk

March 29, 2024

ICBA said the Basel Committee on Banking Supervision’s framework for classifying cryptoasset exposures validates community bank misgivings about cryptocurrencies.

Background: The Basel Committee’s consultative document proposes revised standards for stablecoins to qualify for the most preferential capital treatment. The proposal would establish strict standards—each of which would need to be met to qualify for preferred treatment—and would exclude any cryptoassets that operate on permissionless networks.

ICBA Comments: In a comment letter on the Basel Committee’s consultative document on cryptoasset standards, ICBA said:

  • The proposal represents an accurate assessment of key risk factors associated with stablecoins, validating ICBA’s view that stablecoin instruments do not provide any advantages over the existing U.S. banking system.

  • It strongly agrees with Basel’s assessment of the risks arising from permissionless networks, which would apply to all major stablecoins and raise questions about the functions of stablecoins that cannot be carried out by other methods.

  • While the revisions may limit banks’ exposure to stablecoins, they are unlikely to shield the financial system from disintermediation by the crypto ecosystem, so additional actions to confront the hazards of stablecoins are needed.

Latest on Crypto: Shortly after ICBA submitted its comments, FTX founder Sam Bankman-Fried was sentenced to 25 years in prison for defrauding his cryptocurrency exchange’s customers and investors, the Financial Action Task Force warned that jurisdictions across the world are failing to regulate crypto, and Bloomberg reported that U.S. and U.K. law enforcers are investigating Russian use of Tether to evade sanctions.

ICBA Advocacy: In a recent comment letter, ICBA told the Financial Crimes Enforcement Network that it should strengthen its proposal to institute recordkeeping and reporting requirements for financial institutions, which is insufficient to adequately protect against crypto-related illicit financial activity. ICBA also supports additional global efforts to advance international cryptoasset regulation, including the Financial Stability Board’s framework to support consistent regulatory standards and the International Organization of Securities Commissions’ baseline policy recommendations.